The South African Forestry Industry has long relied on agrochemicals, particularly pesticides, to ensure healthy plantation productivity and comply with national legislation governing landowners in South Africa. But with sustainability under the spotlight and environmental compliance tightening, the introduction of Extended Producer Responsibility (EPR) regulations under the National Environmental Management: Waste Act (No. 59 of 2008) now places legal and environmental responsibility squarely on the shoulders of producers, and this includes the proper disposal of pesticide containers.

The EPR Regulations, effective from 5 May 2021, require producers, importers and brand owners to take full lifecycle responsibility for their products. This includes collection, recycling and safe disposal of waste associated with those products. While forestry companies may not be “producers” under the legal definition, they are key stakeholders in the EPR value chain.

For the Forestry Industry, a critical area of concern is the disposal of empty pesticide containers, which often contain toxic residues and can be considered hazardous waste if not cleaned and handled correctly.

Improper disposal of pesticide containers, such as burning, burying, or reuse for household purposes, poses a serious risk to:

• Soil and water systems through leaching of chemical residues
• Human health, especially among workers or surrounding communities
• Biodiversity, due to contamination of ecosystems

The EPR regulations aim to eliminate these risks by formalising the return, collection and treatment processes for such containers.

Under the EPR framework, responsibility is shared across the supply chain, but the primary burden rests with the producer, defined in the regulations as:

• Manufacturers or importers of pesticide products
• Companies placing pesticides on the South African market under their brand
• Retailers who sell imported or own-brand products

These producers must now:

1. Register with the Department of Forestry, Fisheries and the Environment (DFFE)
2. Develop and implement an EPR scheme or join an existing Producer Responsibility Organisation (PRO) (such as CropLife SA’s scheme for pesticide containers)
3. Ensure take-back systems are available and accessible
4. Fund the collection, transportation and environmentally sound disposal or recycling of empty pesticide containers

• Only triple-rinsed containers are considered non-hazardous and acceptable for recycling or collection.
• Record keeping is essential, forestry operations must track container use and disposal as part of environmental compliance audits.
• Worker training is crucial to ensure pesticide handlers understand proper cleaning, storage and return protocols.
• Engagement with suppliers and PROs (e.g. through TIPWG or CropLife SA) helps ensure alignment and smooth collection processes.

The EPR regulations mark a new chapter for environmental compliance in forestry. While they place a legal obligation on producers, their success relies on collaboration across the industry, from chemical manufacturers to foresters in the field.

By managing pesticide containers responsibly, the Forestry Sector protects ecosystems, improves worker safety and builds public trust in its environmental credentials. As stewards of the land, this is a responsibility we must all take seriously; from the first drop of pesticide to the last empty container.