The war on improper solid waste management in Kenya made more significant steps this month with the launch of a polyethylene terephthalate (PET) bottles take back scheme recovery initiative by Kenyan manufacturers which hopes to consolidate efforts around minimizing the PET waste footprint in the country. Kenya imports around 20,000 tons of PET products annually with only less than 5% of these being recycled despite Kenya having a basic recycling system. The low uptake of recycling is largely attributed to lack of a proactive recovery process which Kenya Association of Manufacturers through a company known as PETCO seeks to address. Currently, PET recovery relies mainly on informal collectors who pick the bottles from the streets and also ‘scavenge’ at illegal dumps and landfills and sell these to unregulated plastic collectors who in turn sell to recyclers. Sorting at the source of generation which would make the job more efficient and humane for these informal collectors is largely nonexistent.

These are the conditions on the ground as PETCO takes on this timely job of cleaning the environment off PET waste. It is not lost to observers that this initiative comes on the backdrop of a hugely successful implementation of the ban on plastic carrier bags which turns one year in a few months. Following this success, the Government of Kenya last year proposed the banning of PET bottles and gave manufacturers six months to come up with a plan that would reduce PET waste in the country. PETCO is, therefore, a product of negotiations between the Government of Kenya and manufacturers and follows the global trends of adoption of the Extended Producer Responsibility (EPR) concept where manufacturers bear a significant degree of responsibility for the environmental impacts of their products throughout the product life-cycle.

In a provocative letter published in November 2016 titled ‘DEMANDING FMCG CORPORATIONS DECLARE WASTE MANAGEMENT PLANS FOR THEIR PACKAGING MATERIALS’, I argued that manufacturers are solely responsible for the packaging they produce to deliver their commodities to consumers and they should wonder and even worry how these materials are disposed of. They should have a waste management plan for every single piece of packaging they produce. These packaging materials ultimately belong to the factories that produced them, I argued. The manufacturers should, therefore, take note of the upstream impacts inherent in the selection of materials for the products, impacts from the manufacturers’ production process itself, and the downstream impacts from the use and disposal of the products. I even went ahead to argue that a manufacturer of a soft drink, for example, should feel disturbed if any of their packaging were to be found on Mt. Kenya! The establishment of PETCO, therefore, validates this opinion and I personally wish this initiative succeeds. Let me, however, make some observations.

Lack of EPR laws to hinder Kenya manufacturing proposed take-back scheme for PET

First, the adoption of EPR in the management of PET should have gone beyond negotiations between Kenya Association of Manufacturers and the Government of Kenya to involve other stakeholders and should have also extended to other non-plastic products such as e-waste, glass, tyres, and batteries waste, among others. There are many non-business stakeholders in this industry from whose knowledge base the project would have benefited. This is particularly for environmental conservation practitioners, adversely affected communities and civil society. It does seem that Kenya has adopted a ‘negotiated PET EPR model’ where companies are not obligated to participate. There are around 400 EPR schemes in operation across the world, most of which are mandatory. Within Europe, packaging, electrical and electronic goods, batteries and cars are all subject to EPR requirements through various EU directives. Outside of Europe, Japan has an extensive EPR law that covers the lifecycle of products from various industries – part of this legislation requires manufacturers to use recycled materials and reusable parts in new products.

As far as I can tell, the KAM-PET model is not therefore grounded in any known legal EPR framework. Other countries adopted a hybrid model. In my 2016 letter, I proposed this model with both the National Environmental Management Authority and Kenya Association of Manufacturers playing a critical role. While all models have their pros and cons, KAM-PET Extended Producer Responsibility model is welcome and will evolve to provide data for a more comprehensive Kenya EPR legislation which I now support.

Manufacturing proposal on PET management is very broad

Secondly, it is not clear how the KAM-PET Extended Producer Responsibility initiative will be implemented. There are very broad suggestions of a ‘take back scheme’, support of ‘cleanup initiatives’ and ‘public awareness’ involving counties. Hopefully, in the coming months, this strategy will become more lucid and contribute meaningfully to the general solid waste management facing Kenya. What is of no doubt is the window of opportunity this development has provided for Kenyan manufacturing and to a large extent, all organizations to become more forward-looking as regards sustainability issues. This is something we must all celebrate.

An effective infrastructure, systems view and design intention required

Let me now speak to the three broad suggestions KAM-PET Extended Producer Responsibility addresses. First I’m assuming that the ‘take back scheme’ will be implemented parallel to the existing waste disposal and collection processes that already exist. This suggests KAM on its own or through its members or agents will install collection points across the country in all levels of size and automation where citizens will deposit PET bottles. Already some companies have already started doing this. The assumption is that the companies will then on their own or through a Producer Responsibility Organization (PRO) organize collections from these drop-off points for further conveyance. This scenario is very problematic.

First, such a scenario requires a strong and effective infrastructure, systems view and design intention. This would require considerable investment. Already there appears to be a lack of openness about how this scheme will generally work and how many organizations have signed up giving little understanding of the actors in the value chain. Which begs the questions, is this scheme being designed to consolidate the existing business models based on the logic of growth of economics or is it part of a systemic process of change that incorporates sustainability? Simply put, will this scheme merely benefit the PRO (the recycler), who will no longer have to pay the ‘scavengers’ for the collected PET bottles? Or better still what is the value-added to the already existing process given that most of these take-back receptacles are to be installed in established facilities like malls where solid waste management is already a priority?

Secondly, globally there appear to be few examples of a successful ‘PET take back scheme’ that does not also incorporate a ‘deposit scheme’ where consumers get a refund for returned PETs. The widely quoted South African mock-up for which PETCO is modeled is also very different from our circumstances. If we wanted any examples we needed to have looked no further than Nakumatt. Several years ago, Nakumatt supermarkets experimented with this model by installing giant drop off points near their facilities as well as segregated litter bins across major towns as part of a campaign dumped ‘Go Green Buy Blue’. Such initiatives promote proper disposal by citizens and reduce acts of littering and illegal dumping. It is, however, important to investigate whether litter segregation is adhered to in a way that adds value to the PET ‘take back scheme’ and whether the design of the PET collection receptacles would encourage good behavior and whether their upscale would contribute tremendously to the reduction of the PET waste footprint. There is also the small question of whether these receptacles would be practical in populated informal settlements where most of the uncollected waste lies.

The KAM-PET take back scheme has therefore not been canvassed properly in terms of its applicability, relevance and deliverability. To put it simply, we are talking of an ordinary citizen from Umoja in Nairobi or Kongowea in Mombasa taking PET bottles from the house to a ‘take back scheme’ point at a nearby supermarket or petrol station. Why would they do that if they can have an existing garbage collection initiative either by a local authority, a garbage collection company or a community initiative pick from his house? Or would investing in home segregation incentives or training be more prudent? Or as I mentioned above, the whole concept has been designed to benefit the recycler from opportunity costs? If that is the case, then, shouldn’t we have the PROs bear the cost of installing and managing these receptacles?

Most PET bottles that find their way into our waterways and ecosystem are often from travelers on our roads who throw waste from the windows, or those walking where there are no bins or from illegal dumps where no proper and enforceable waste disposal or collection system is in place or even from rogue companies who dump by the night. We have to salute the informal PET waste collectors, who ‘scavenge’ for the bottles at any level of the chain, whether at the household, establishment, collection point, in transit or at dumpsites. Perhaps a campaign to make their work more humane and efficient is more than timely. KAM can do this by providing training, safety equipment and even supporting community value chain activities where these PET collectors can do their own sorting and shredding to increase their gains from this environmental effort.

Or better still, as I have always argued, a campaign to discourage people from littering the highways or engaging in acts of illegal dumping needs to be seriously prioritized. This can be done in partnership with the Public Service Vehicles (PSVs) industry, Truck drivers and other road users. National Transport Services Agency (NTSA) and PSVs Saccos can be encouraged to implement the requirement of availability of dustbins which can then be emptied at legal drop off points along the highways with drivers encouraged to remind travelers that littering on the highways is illegal. KAM can also participate in substantial investment in behavioral change initiatives to get Kenyans to alter how we handle and dispose of litter. I have often lobbied for a well funded collaborative national campaign as the first starting point to anyone who cares to listen. This can be supported by ongoing community and school projects. And finally, KAM should consider going beyond the PET bottles approach. Becoming a true stakeholder in Kenya’s environmental project with Government and other stakeholders in a strategic, collaborative, inclusive, less reactive and innovative manner beyond the traditional knee jerk approach will help deliver the idea of a clean, litter-free, conducive and safe Kenya.

Otherwise, if these points are not considered, KAM-PET ‘take back scheme’ will simply become another big lie!