After five years of mandatory Extended Producer Responsibility (EPR) in South Africa, there is considerable pressure to move away from a compliance only mindset towards measurable environmental progress.

One of the ways that EPR aims to achieve this measurable progress is for producers to conduct lifecycle assessments (LCAs) on the products they place on the market, taking more responsibility for how the products are produced as well as disposed of. According to the Council of Scientific Research (CSIR), which developed the guidelines for LCAs, conducting an LCA is not a data developing exercise, but a procedure rooted in revaluating design processes and material choices in order to shift linear products towards the circular economy.

A LCA is a structured methodology used to evaluate the environmental impacts of a process, service, or product from the extraction of raw materials through manufacturing, converting, distribution, use and end-of-life, including recycling or disposal. Often referred to as a “cradle-to-grave” assessment, an LCA can be used to identify where the highest environmental impacts occur and thereby highlight opportunities for improvement.

For producers, LCAs provide evidence-based insights that support better decision making. Rather than relying on assumptions, businesses can quantify impacts such as carbon emissions, water consumption, energy use, climate change, and resource efficiency, among others.

This can assist manufacturers in designing packaging that is not only more sustainable, but also more competitive in an increasingly environmentally conscious marketplace.

Which producers are required to conduct an LCA?

The requirement applies to producers of packaging operating under South Africa’s EPR Regulations who place identified products and packaging on the market. These regulations require packaging producers to ensure that life cycle assessments are undertaken as part of their broader environmental performance obligations.

Under South Africa’s EPR regulations, specifically Regulation 5(1)(k), packaging producers are legally required to conduct an LCA for their products, in accordance with applicable standards, within 5 years of the implementation of their EPR scheme. For the paper and paper packaging sector, this is not an open-ended suggestion; it is a hard regulatory milestone.

But Regulation 5 does not merely mandate any generic environmental assessment. Regulation 5(1)(l) strictly dictates that these LCAs must focus on three areas of environmental performance:

1. Minimisation of material used in the identified product.
2. Designing the product to facilitate reuse, recycling, or recovery without compromising its primary functionality.
3. Reducing the environmental toxicity of the resulting post-consumer waste stream.

For affected brands, this means that compliance cannot be achieved with a generic, off-the-shelf LCA or a quick checklist. The assessment must be a precise, product-specific diagnostic that proves a producer is actively working to minimise raw material consumption, design circularity, and purge toxicity from the waste stream.

Crucially, because an LCA is a complex scientific undertaking that can take months to complete, waiting until the eve of the regulatory deadline to engage is risky.

Beyond regulatory compliance, LCAs are valuable business tools that help manufacturers design products with sustainability in mind.

By identifying environmental “hotspots”, producers can evaluate alternative raw materials, reduce unnecessary packaging, improve recyclability, increase recycled content, and optimise manufacturing processes. These improvements often result in lower production costs, greater resource efficiency, and reduced environmental impacts.

As consumer expectations and international sustainability standards continue to evolve, LCAs can provide businesses with valuable information to inform sustainability related decisions. When considered alongside economic and social factors as part of a broader decision-making process, these considerations can help businesses remain competitive while contributing to South Africa’s transition to a circular economy.

As the leading Producer Responsibility Organisation (PRO) for the paper and paper packaging sector, Fibre Circle is helping its members prepare for the growing importance of LCAs. Rather than expecting each producer to independently develop all the technical expertise and resources required to conduct LCAs, Fibre Circle is taking a collaborative approach by providing guidance, facilitating industry collaboration, promoting consistent methodologies, and improving access to environmental data

According to a 2026 report by the CSIR, Fibre Circle’s members collectively place 95%-96% of the locally consumed packaging papers in South Africa on the market. This represents an opportunity to collect a large amount of data and make a real shift in how paper packaging is designed and disposed of in South Africa.

The organisation is also driving initiatives such as the South African Repulpability and Recyclability Standard, which complements LCA work by encouraging packaging designs that are more recyclable and better aligned with South Africa’s recycling infrastructure.

The message to producers is clear: An LCA should not be viewed simply as a compliance requirement. It is a strategic business tool that helps identify opportunities to reduce material use, improve resource efficiency, eliminate unnecessary environmental impacts, and design packaging that is better suited to a circular economy.

By using LCA findings to inform product and packaging decisions, businesses can strengthen regulatory compliance, prepare for future policy developments such as eco-modulated EPR fees, lower material costs, and build brands that demonstrate genuine environmental stewardship. Five years into South Africa’s EPR journey, LCAs have become an important driver of innovation, competitiveness, and long-term sustainability within the paper and paper packaging sector.