What's changed in South African waste, EPR and air quality compliance

The Extended Producer Responsibility regime has moved twice in recent years: coverage was extended in March 2023 beyond paper, packaging, electrical and electronic equipment and lighting to include portable batteries, lubricant oils and pesticides, and the underlying 2020 Regulations and sector notices were further amended by notice in November 2024. The waste management activities schedule under the Waste Act 59 of 2008 has also been amended several times, most recently including a 2022 amendment, so licence-trigger thresholds should not be assumed static.

Reviewed by TefCo Compliance Research — last verified 15 September 2026.

In short

EPR: wider coverage, amended regulations

The Extended Producer Responsibility Regulations, 2020 came into effect on 5 May 2021 for paper and packaging, electrical and electronic equipment, and lighting. In March 2023, the regime was extended to cover portable batteries, lubricant oils and pesticides, bringing the total to six regulated product streams.

The Department of Forestry, Fisheries and the Environment gazetted a further amendment to the EPR Regulations and the sector notices on 6 November 2024, adjusting definitions used across the scheme (including 'extended producer responsibility fee' and 'extended producer responsibility funding'). Producers and Producer Responsibility Organisations should work from the amended definitions rather than the original 2020 text.

EPR sector notices and definitions have been amended more than once since 2020. Before setting a fee structure or a monitoring programme, confirm you are working from the version of the Regulations and sector notice currently in force.

The Waste Act's own amendment history

The National Environmental Management: Waste Act 59 of 2008 has itself been amended by the National Environmental Management: Waste Amendment Act 26 of 2014 (which established the Waste Management Bureau and a pricing strategy), the National Environmental Management Laws Amendment Act 14 of 2013, the National Environmental Management Laws Amendment Act 25 of 2014, and — most recently — the National Environmental Management Laws Amendment Act 2 of 2022, which came into effect on 30 June 2023.

The listed activities schedule keeps moving

The schedule of waste management activities requiring a licence under section 20 of the Waste Act, originally gazetted in 2013, has been amended by further notices in 2014, 2015, 2017 and 2022, each adjusting which activities and throughput thresholds trigger a licence versus a lower-tier registration under norms and standards.

Air quality reporting stays on the same annual cycle

No change was found to the 31 March annual NAEIS reporting deadline or to the requirement for AEL holders to submit an annual report with an independent compliance audit. Operators should still confirm their own facility's classification and reporting obligations directly with the licensing authority, since minimum emission standards under the Air Quality Act 39 of 2004 have themselves been amended over time.

Frequently asked

Do pesticide producers now have EPR obligations?

Yes. Since the March 2023 extension of the EPR regime, pesticides sit alongside portable batteries and lubricant oils as regulated product streams, in addition to the original paper and packaging, EEE and lighting streams.

Has the SAWIS reporting cycle itself changed recently?

A 2018 draft proposed shortening the quarterly submission window under the National Waste Information Regulations, but the reader should confirm the currently gazetted reporting cycle on the SAWIC portal rather than assume either the original 2012 timeframe or the 2018 draft applies.

Sources

TefCo Corporate Compliance (Pty) Ltd is a compliance management platform, not a legal, tax or advisory firm. This guide is general information, not advice. Fees, dates and thresholds change — confirm current figures with the regulator before you rely on them.

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