Keep these EPR regulations for waste management in mind

March 2025

DR GERHARD H VERDOORN, STEWARDSHIP AND OPERATION MANAGER, CROPLIFE SA. FIRST PUBLISHED IN SA GRAAN/GRAIN, NOVEMBER 2024.

SOUTH AFRICA IS NO DIFFERENT THAN MOST OTHER COUNTRIES IN THE WORLD WHEN IT COMES TO WASTE. WE AS CITIZENS POLLUTE THE ENVIRONMENT WITH SOLID AND LIQUID WASTE TO THE POINT WHERE THE ENVIRONMENTAL AUTHORITIES (DEPARTMENT OF FORESTRY, FISHERIES AND ENVIRONMENT, OR DFFE) HAD TO PROMULGATE REGULATIONS TO BRING SOME ORDER INTO SOCIETY AND REDUCE WASTE.

The DFFE went about their business in quite an ingenious way by placing the onus for waste management systems upon the farmers of commodities. This is what is known as the extended producer responsibility (EPR) regulations, which require that farmers of commodities must devise mechanisms and infrastructure to allow end users of their products to dispose of the waste of such products in an environmentally responsible manner.

A sectoral approach was taken by the DFFE. For example, in the case of pesticides, a special notice was promulgated by the DFFE to place a ‘burden’ (read here more of a responsibility) on the pesticide industry to have ways and means of collection and disposing of empty pesticide packaging and redundant (obsolete) pesticides.

Triple rinsing according to the CropLife SA triple-rinse protocols.

EPR SCHEME FOR THE PESTICIDE SECTOR
The EPR scheme for the pesticide sector is one of many similar notices that have been developed by the DFFE, with the aim of reducing, re-using or recycling waste. A similar set of regulations was promulgated for the electronics industry to reduce the quantity of electrical appliances being dumped at landfills in the country. Perhaps the biggest difference between the pesticide industry and other industries is that it has two waste streams, namely obsolete pesticides that are hazardous substances and empty pesticide packaging that may be hazardous, depending on how the packaging is managed.

In the EPR scheme for the pesticide industry there is a direct instruction to any person or company who produces a pesticide or pesticides to register itself as such with the DFFE’s South African Waste Information Centre and to establish a producer responsibility organisation (PRO) to manage empty pesticide packaging and obsolete pesticides at the post-consumer stage. In simple terms, the requirement of the DFFE for pesticide farmers is to have an organisation that can assist end users of pesticides, such as farmers, to dispose of empty packaging and obsolete pesticides.

The regulations allow for pesticide farmers to operate singularly or collectively, which means that a pesticide producer must have a system and infrastructure through which end users can get rid of their pesticide packaging and obsolete pesticides, or join an existing establishment (PRO) that has systems and infrastructure to perform the functions of pesticide waste management.

THE FARMER’S ROLE
Farmers, like the general consumer (in fact all of us), are waste generators. Much of the waste generated on a farm is general waste, and farmers are compelled by law to dispose of waste in a responsible manner, as dictated by the National Environmental Management: Waste Act (NEMWA).

The problem for the farmer lies in pesticide waste because, as mentioned earlier, pesticide waste (packaging and obsolete pesticides) is hazardous or potentially hazardous. The NEMWA and SA National Standard 10206 prohibit the burning or burying of hazardous waste. This is not an unreasonable prohibition – any such action pollutes the environment and poses a severe risk to human health. What options are then available to a farmer to dispose of empty pesticide packaging and obsolete pesticides?

CropLife SA is currently registered as the only pesticide PRO (registration number: 19/7/5/P/PRO/20230428/038). It has a very large network of CropLife SA-certified recyclers that operate all over the country to receive and recycle nominally empty pesticide packaging – mostly the High Density Poly Ethylene (HDPE) drums. Here, the catch phrase ‘nominally empty’ is the key element of CropLife SA’s commitment and plea to farmers: Make sure that all pesticide packaging is cleaned according to the container management guidelines, which are available on the CropLife SA website at https://croplife.co.za/Home/ContainerManagement.

Most farmers already know about the triple-rinse principle – rinsing an empty container three times with clean water and decanting the rinse water into the spray tank, after which the container must be punctured to render it unsuitable for other uses. Such packaging is not hazardous and will be accepted by the CropLife SA-certified recyclers. Therefore, the balance in the equation lies between the farmer and the CropLife SA PRO – one generates a clean, general waste product, and the other takes it over and recycles it.

The CropLife SA PRO and its associated recyclers are funded by the pesticide farmers who are subscribers of the CropLife SA PRO and who pay an annual subscription fee (also called a waste management fee). This fee is used to subsidise the recycling efforts with administrative support, equipment, consumables, infrastructure and logistics to collect and recycle nominally empty pesticide packaging. Approximately half of the funds generated is used to dispose of obsolete pesticides.

The cost of obsolete pesticide disposal is very high because these products have to be incinerated at a fee of more than R20 000/metric ton. A question that may arise from farmers is how the regulations and the CropLife SA PRO benefit them? The cost of the disposal of empty pesticide packaging is not for the farmer’s pocket – it is for the CropLife SA PRO’s account. In future, the PRO will also collect and dispose of obsolete pesticides, which would have cost farmers an enormous amount of money.

Key points for farmers in terms of the EPR regulations

1. EPR regulations place an onus on pesticide manufacturers to have a system and infrastructure in place to manage pesticide waste at the post-consumer stage, also known as end-of-lifecycle. However, it does not abscond waste generators of their duties to dispose of pesticide waste responsibly and according to the statutes of the country.
2. Farmers must insist that their crop advisers guide them on the appropriate cleaning of pesticide packaging and where the closest CropLife SA-certified recycler is situated.
3. Empty pesticide containers and obsolete pesticides should never be burned or buried.
4. All farmers have a right to question whether a pesticide producer (manufacturer or supplier) is a subscriber of the CropLife SA PRO. If the supplier is not, the CropLife SA PRO is under no obligation to manage his packaging and obsolete pesticides at the end of their lifecycles.
5. Farmers have the right to request assistance from the CropLife SA PRO in terms of hurdles experienced with empty packaging and obsolete pesticides.

ADVANTAGES FOR SOCIETY AND THE ENVIRONMENT

• Farmers may not realise it, but the pesticide containers from the agricultural sector supply career opportunities for hundreds of people. The recyclers are not the only ones benefitting – it is also their workers and people in companies who manufacture other goods from the recycled plastic.
• CropLife SA’s motto for the recycling effort – ‘It’s the right thing to do’ – carries more weight than simply a few words. It has a message of clean farms, job opportunities and adherence to the waste management regulations of South Africa. South Africa is one of only two countries in the world that manufactures new pesticide containers from recycled container materials.
• South Africa is also under the top five countries in the world with success in the recovery and recycling of empty pesticide containers. Is it not time for all farmers to take South Africa to be the world leader with the recovery and recycling of empty containers? We can do it, down here in the southernmost country in Africa. It is the right thing to do!  

For more information, contact the CropLife SA stewardship and operation manager, Dr Gerhard Verdoorn, on 082 446 8946 or gerhard@croplife.co.za.

Publication: March 2025

Section: Pula/Imvula