CONSULTATION BRIEF
Start date: 3 February 2026
Closing date: 27 April 2026
Title of the public consultation: Implementation of Extended Producer Responsibility obligations on certain non-packaging paper products
Ministry: Ministry for the Environment, Energy and Public Cleanliness (MEEC)
Entity: Environment and Resources Authority (ERA)
- Background
Non-packaging paper (NPP) represents a significant share of paper placed on the market of Malta, which, upon becoming waste, needs to be managed in a cost-effective and environmentally-sound manner. To date, such waste is being handled through existing separate collection and treatment systems, which are, however, financed by producers of packaging through the permitted Producer Responsibility Organisations (PROs). In order to address this issue, thus also ensuring a fair implementation of the polluter-pays principle, Malta’s Long Term Waste Management Plan (2021–2030) (WMP) contains a measure (i.e. WMRO_EPR29) that provides for the enactment of legislation establishing a national Extended Producer Responsibility (EPR) scheme for NPP.
Article 8A of Directive 2008/98/EC on waste (the Waste Framework Directive – WFD) establishes common rules when Member States (MS) decide to set up an EPR scheme at the national level. As part of the suite of such rules, MS are to set waste management targets in line with the WFD, establish a reporting regime and ensure the producers cover the applicable EPR costs.
The draft Legal Notice (LN), which is based on the findings of a feasibility study, aims to establish a mechanism whereby producers of the targeted NPP products cover the costs of the management of municipal NPP waste through the existing separate collection (i.e. the grey bag and recycling points) and treatment systems set up by the Regional Councils for municipal packaging waste.
To minimise the costs on the concerned industry, the draft LN requires producers of the targeted NPP products to fulfil EPR obligations through the existing PROs for packaging waste, namely to cover the costs of separate collection, transport and treatment; awareness-raising; and data gathering and reporting.
The NPP products falling under scope of this draft LN are:
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- A3 and A4 photocopy paper;
- Advertising and commercial printed materials, excluding those that are printed locally on the A3 and A4 paper sheets covered under the first point;
- Newspapers, journals and periodicals;
- Envelopes, letter cards, plain postcards, correspondence cards, printed or illustrated postcards, printed cards bearing personal greetings, messages or announcements, whether illustrated or not;
- Registers, account books, notebooks, order books, receipt books, letter pads, memorandum pads, diaries and similar articles, exercise books, blotting pads, binders, folders, file covers, manifold business forms, interleaved carbon sets and other articles of stationery; albums for samples or for collections and book covers.
The following educational materials are excluded from the draft LN, where they are exclusively devoted to learning and cultural diffusion:
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- Books, including drawing and colouring books, workbooks and activity books that support classroom instruction;
- Music printed or in manuscript form; and
- Maps and hydrographic or similar charts.
The LN also allows producers of newspapers, journals, and periodicals to apply for an exemption from covering waste management costs, provided they include public information in their physical publications on waste prevention, separation, separate collection, and recycling, with a frequency prescribed in the draft legislation.
In line with Article 8A of the WFD, and noting that Regional Councils have already set up separate collection and treatment systems and are responsible to attain the recycling targets on municipal packaging waste, the draft LN sets recycling targets on municipal NPP waste to be attained by Regional Councils, which shall also integrate data on such waste in their reports to ERA on packaging waste.
- Consultation
In line with Article 55 of the Environment Protection Act (Cap. 549), the public is invited to make submissions to ERA with their comments as to why and how these draft regulations could be amended.
- Documents
Extended Producer Responsibility (Non-Packaging Paper) Regulations, 2026
- Submission of feedback
Comments are being invited through the feedback form at publicconsultation.gov.mt or otherwise by email through [email protected] by no later than 3 March 2026.
In addition, an online stakeholder and public consultation session will be organised by ERA on 16 February 2026 from 13:30 to 15:00, wherein the draft LNs will be presented. The presentation will be followed by a Q&A session wherein stakeholders and members of the public may provide feedback. Interested stakeholders and members of the public are invited to register for this meeting from the following link.
- Further notes
Please be informed that comments submitted, together with the identity of the contributor, may be published online at the end of the public consultation, unless the contributor objects to the publication of his/her personal data. In this case, the contribution may be published in anonymous form.
All comments submitted shall be duly considered.
