May 28, 2020

An update on the Lighting Industry Waste Management Plan Date March 2020

Lightcycle SA is a non-profit producer responsibility organisation (PRO) established in 2018. The organisation’s objective is to promote the compliant and sound end of life management of lighting and associated equipment with accredited service providers for efficient collection, transportation and recycling. Lightcycle SA developed the Lighting Industry Waste Management Plan which details the requirements for the implementation of responsible and holistic post-consumer lighting waste management throughout South Africa. Patricia Schröder on behalf of Lightcycle SA NPC updates Sparks Electrical News readers on the latest developments.


The Minister published a revised S28 Notice on 12 September 2016. After due consultation with industry, the Minister published a Final Notice on 6th December 2017, calling on the Paper & Packaging Industry, Electrical & Electronic Industry and the Lighting Industry to submit IndWMP’s (industry waste management plans) by 5th September 2018. Plans that were received:

The Department received the following plans from the three sectors:

  • Paper & Packaging: 7 Plans
  • Electrical & Electronic: 5 Plans
  • Lighting: 1 Plan (Lightcycle SA NPC)

Two submissions were submitted after the due date and were thus not accepted.

Current status in summary

A meeting was called for the 9th December 2019 by the Department of Environment, Forestry and Fisheries (DEFF), with the Producer Responsibility Organisations (PRO’s) that submitted plans. The Director General, Ms. Nosipho Ngcaba chaired the meeting.

The Director General announced that the Minister will withdraw all submitted S28 Plans. Ms Ngaba reported in the meeting that “throughout the entire process it has become abundantly clear that none of the plans meet the criteria of a Government Managed Model, and that a Section 28 plan is therefore no longer the best route to take. In order to expedite the process, she would like to return to the drawing board as soon as possible to develop a workable plan. Receiving the support and buy-in of the industry is vital if this plan is to succeed.” Lightcycle SA’s withdrawal notice was received on the 12 Dec 2019, citing the reasons for withdrawal.

The DG also confirmed that the Minister would shortly issue a notice of withdrawal of the S28 Notice and replace the S28 notice with the S18 (1) notice.

Ms Ngcaba explained that a framework needed to be developed that would include clear targets for each sector, with quarterly and annual reporting, the minimisation of waste and encouragement of recycling. The first of these engagements will take place early in February 2020 and will require input in terms of a possible structure and future cooperation between industry and Government.

The Minister called for the relevant industries to submit comments on the proposed framework of the Extended Producer Responsibility (EPR) scheme with the deadline of submissions being the 27th January 2020. Lightcycle SA NPC submitted comments within the timeframe.

The minister invited the PRO’s and stakeholders to engage with DEFF in workshops to develop the framework for the Section 18 (1) EPR Scheme, the first of these engagements took place on the 12 February 2020. All producers/individuals were invited via IESSA that are registered on its database. Within the lighting group of attendees, 83% were producers and 17 % comprised of other stakeholders.

The aim of the workshop was to discuss the development of a framework for the e-waste and lighting waste EPR Schemes, as per section 18 of the Waste Act. The DEFF split the meeting into lighting and EEE groups. The agreed initial outcomes were recorded as follows: The existing Lighting PRO established by the Lighting Industry, Lightcycle SA NPC, will manage all the aspects of Lighting EPR implementation as the only PRO/EPR Scheme nationally for South Africa. The lighting industry stood firm that no other EPR scheme i.e. EEE will manage lighting. The EPR fees will be collected by the lighting PRO and disbursed to meet the requirements as established. The next workshop dates to continue the balance of the framework items, will be communicated when this is received from DEFF.

Separate to the DEFF process above an Industry meeting and a subsequent Industry workshop will be planned, where all producers are encouraged to attend. Details of this will be communicated via Lightcycle SA in due course.

The way forward

The Section 18(1) notice calls for an Extended Producer Responsibility (EPR) scheme. This would allow for an industry-managed plan as opposed to a government-managed plan.

Lightcycle SA NPC welcomes the Minister’s insight and decision. Even though a considerable amount of time, money and effort has been invested to prepare and submit the Lighting Industry WMP, which represents the entire lighting industry, Lightcycle SA believes the Minister has made the right decision. The plan will serve as the baseline for the future EPR implementation.

Lightcycle SA has always advocated for an industry-managed plan where the producers of lighting are held responsible for managing their waste through belonging to an industry body that represents their interests. For this reason, it is beneficial that the industry be left in charge of its own funds and projects, albeit with very close co-operation and direct accountability to Government.

Lightcycle SA NPC will provide updates on a regular basis to the lighting industry members registered on its database.

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