LFMI’s analysis of certain articles of the Law on Packaging and Packaging Waste Management

It is stated in the draft law that “the licence for the management of waste oils, waste electric and electronic equipment, vehicles unfit for exploitation, waste taxable products or waste packaging shall be issue only to the Organisation, the members of which supply to the domestic market not less than 51 percent of all respective products or packaging supplied to the domestic market.” LFMI recommends rejecting the proposed changes to the law as they would monopolise the market, violate the principles of competition and eliminate the possibility for the activity of and competition among potential economic agents in the market of packaging waste management. The draft law will not ensure a better implementation of the goals sought. LFMI proposes to allow establishing more than one licensed organisation of producers and importers. This would ensure competition on the market, while producers would be able to choose an organisation which would best meet their needs. The permission to establish more than one organisation would not hamper attaining the main goals – to improve the results of waste disposal collection and the transparency of these processes. The established organisations would be able to agree on investments in the development and enhancement of a container or some other effective system of packaging waste collection.