Draft Law on “Extended Producer Responsibility” Open for Public Discussion

Draft Law on “Extended Producer Responsibility” Open for Public Discussion
The draft Law of the Republic of Armenia on “Extended Producer Responsibility” (EPR) has been submitted for public consultation. The draft has been published on the official Unified Website for Legal Acts' Publication.
 
The legislative package aims to introduce the institution of Extended Producer Responsibility in Armenia, requiring producers and importers of certain products (EPR goods) to establish and ensure the proper and safe operation of waste management systems for the specific waste types generated by their products.
 
According to the proposed regulations, Producer Responsibility Organizations (PROs) will be established to implement a financially sustainable, self-financing economic model for collecting necessary funds. These organizations will coordinate interactions with producers, state authorities, and local governments, operating through a combination of environmental, financial, legal, and informational tools.
 
The proposed system is designed to ensure the environmentally sound management of special waste through mandatory procedures such as source-separated collection, secondary sorting (industrial sorting of pre-sorted waste), transportation, storage, placement, reuse, processing, recycling, recovery, disposal, and neutralization — all with minimal impact on the environment, human health, and climate.
 
With the implementation of the EPR system, the volume of waste sent to landfills is expected to decrease, as certain waste types will be reused, recovered, or recycled. The initiative also aims to align Armenia’s waste management practices with EU legislation, especially the relevant EU directives on EPR regulations, models, and updated waste classifications.
 
According to the published document, the volume of waste generated from the sale, consumption, or use of EPR products in Armenia is steadily increasing, with at least 98% of it ending up in unsanitary landfills. Due to the absence of effective economic incentives and institutional mechanisms, only a small portion of this special waste is recycled or recovered — less than 10% of recyclable waste, according to expert assessments. As a result, valuable recyclable waste such as glass, paper, plastic, metal containers, and packaging (e.g., bottles, boxes) loses its economic value as secondary raw material. Furthermore, when mixed with unsorted household waste and contaminated with food scraps and household chemicals (including toxic substances), the waste becomes hazardous to both public health and the environment. Beyond landfills, such waste ends up in natural ecosystems, further harming the environment, human health, and the climate.
 
The draft notes that, as of 2025, Armenia is home to 5 companies processing plastic waste, at least 9 for paper waste, 1 major company for glass recycling, at least 5 for metal recycling, 1 for hazardous automotive waste (tires, oils, filters), and at least 3 companies for the disposal of medical hazardous waste, along with 3 others handling various types of hazardous waste.
 
In November 2024, the Recyclers’ Union* was established in Armenia to inform its members on legislative changes, public policies, and investment programs in the waste management sector, provide feedback to relevant government agencies, and promote the adoption and dissemination of best practices, technologies, equipment, and automated information systems.
 
In 2025, Armenia saw the establishment of the first officially registered Producer Responsibility Organization (PRO) Foundation, initiated by three companies. The PRO works in collaboration with Hrazdan Municipality and relevant government agencies. The companies have made a joint investment of approximately €300,000 to support the PRO’s activities over three years.
 
The draft also includes preliminary estimates on the EPR system’s economic impact on the state. “The introduction of the EPR system can significantly increase public revenues and stimulate waste recycling, private investment, and job creation,”* the document notes. Estimated state revenue per ton of waste includes: 127,092 AMD for batteries, 22,946 AMD for electrical and electronic waste, 5,179 AMD for packaging waste, 51,222 AMD for tires.
 
If all recyclable waste is processed, annual tax revenue could exceed: 2.4 billion AMD from batteries, 458 million AMD from packaging, 968 million AMD from tires, 40 million AMD from electrical and electronic waste.
 
Beyond financial impact, the system is expected to create approximately 450 green jobs, including 347 in the packaging and packaging waste management sector alone.
 
The draft law was developed by the Ministry of Environment of the Republic of Armenia with support from the four-year Sweden-funded “Waste Management Policy in Armenia” project, implemented by the Acopian Center for the Environment at the American University of Armenia.


July 02, 2025 at 16:20