Producer Responsibility
We think introducing producer responsibility in the regulatory landscape is essential to mitigate climate change. Around 90% of global carbon dioxide emissions come from fossil fuel and industry, and 2022 was a record year with 1.0% increase in their attributed emissions. Producers need be responsible for their emissions - we believe they should clean up their waste (yes, the CO2 embedded in their products). One way to regulate this is through the EPR policy called Carbon Takeback Obligation.
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Producer responsibility (PR) is a legal framework that assigns the environmental responsibility for a product to the producer or manufacturer of that product. This means that producers are responsible for the entire lifecycle of their products, including the environmental impacts associated with the extraction of raw materials, the production process, transportation, use, and disposal of the product. This is often applied in plastic or electronics industry.
Whilst PR often focuses on the internalisation of price to reflect the responsibility, we believe that the necessary bit is for producers of CO2 to be responsible for active management of the CO2 in their products. This is Extended Producer Responsibility (EPR).
Under an EPR framework, producers are required to take an active role in the management of a product once it has reached the end of its useful life. For CO2 waste, this would require a take-back requirement. The goal of EPR is thus to reduce the environmental impact of fossil fuels throughout its entire lifecycle, and to shift the burden of managing CO2 away from governments and taxpayers and onto the producers themselves.
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Extended Producer Responsibility (EPR) is a governance strategy to add all of the estimated environmental costs associated with a product (from raw materials to end of use) to the market price of that product. There are many types of EPR, and some forms of EPR require producers to pay for managing the end-of-life of their products, and pay the cost of recycling, and/or cleaning up the effects of their products. In the UK, recent EPR legislation requires battery producers and packing producers to clean up their products after use.
We want this form of EPR to be applied to fossil fuel producers, both on extractors and importers. We suggest a CTBO as a mechanism for this EPR. By place an upstream obligating for the clean-up and storage of CO2, we will ensure the necessary action to meet geological net zero. This form of EPR could be added to regulatory compliance schemes for the fossil fuel industry.
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There is an abundance of climate policies in the global toolkit for climate mitigation. And yet, majority of these policies focus on demand-side shifts and demand-side reduction. There are no climate policies currently that regulate the climate impact and CO2 clean-up of fossil fuel production. We need to regulate the supply-side!
There are various fossil fuel supply-side policies that should be implemented, such as removing fossil fuel subsidies (both direct and indirect) and committing countries/regions/cities to phasing out fossil fuels. The latter could be done with supply-side treaties such as the fossil fuel non-proliferation treaty. And ultimately, many countries will and should commit to phasing out fossil fuel use entirely.
However, whilst we keep pressuring for a global phase-out agreement and whilst we are using fossil fuels globally, we need another supply-side regulation. We also propose the CTBO.
Currently, the fossil fuel industry is getting off the hook. We need to obligate them to pay up and clean up.
Last year, most fossil fuel companies made record-breaking profits and increased their production, both operational and planned. Whilst many argue that the fossil fuel industry is heavily regulated, they are not regulated to actually fix the problem. They need to be forced to pay and store the CO2 embedded in the products they sell. This complements other climate policy, resulting in an ultimate phase-out of fossil fuels! We need a carbon takeback obligation to guarantee geological net zero and to act as a backstop if other policies fail to disincentivise fossil fuel use!