Dr. Geraldine Brennan:

They are big questions. As I said earlier, I have to be mindful of when I am speaking on behalf of CIRCULÉIRE industry members, based on the dialogues we have had and their feeding into the opening statement that we developed for coming here today, and of when I am speaking based on my experience. The financial barriers will differ according to the different sectors. Even though ours is a manufacturing platform, we work across food and drinks, plastics, automotive, medical devices, chemicals, pharmaceuticals and the group that we cluster together as the second life enablers. They will have different pinch points with regard to what the financial barriers are, so it is challenging to speak about the financial barriers in a general sense.

One of the things that many small and medium enterprises, SMEs, say, and I am speaking about SMEs rather than a sector, is that the compliance burden, regardless of any new compliance, is already substantial. It means that when one asks them to comply and they do not have the reporting infrastructure set up - they are still paper based - that burden can make it challenging for them to innovate. They know they need to, they know there is a resiliency driver and they know there is the resource price volatility. Some of them have felt that during Covid. That is a very strong driver towards saying, "I have to get my head around this". Ultimately, in going towards action those financial barriers can be many because of the capacity of the companies themselves.

What we see as well is that this is a culture and mindset change for organisations. We have many of the champions in the network. Through our founding members, in particular, where we have gone and done assessments, we have been saying: "It is not going to work if it is just you. Everyone needs to understand what the circular economy means because it affects every aspect of your business". There is that piece of work to be done to embed this within an entire organisation, and that is a cultural transformation process. Anyone who has worked in change management knows that it takes time to create the space to have those conversations, and then there are the day jobs that people have. In terms of the financial barriers, there are the regulatory aspects where some companies have that competence and some of them do not. There are new competences required. There is the change process that is required.

In terms of trying to put this into the Bill, with the circular economy the devil is in the details. That is why in response to the other question from Deputy Bruton about whether we can put these targets in now and whether we can put more in the Bill now, I would be wary, as somebody who has worked in this space and not speaking for the industry members. There are so many nuances depending on the sectors, so trying to have a generic statement about these things could be very challenging. It is about how to find the balance between having a strong intent, then a review and ensuring there is holding to account but without trying to be so general that it is not serving the purpose and intent behind the specifics.

With regard to regulatory certainty and why it matters, it comes back to the idea of a level playing field, which Deputy Bruton highlighted. CIRCULÉIRE is 37 actors out of thousands of businesses. For some of those companies, going after the circular economy model ahead of others could sink their business if they fail. The Senator highlighted maximising profits. The circular economy will bring medium- to longer-term gains, but one has to navigate the bumps to get to those gains. That is the piece where there is this tension between how to support companies and support them to take those risks because that is a fear for businesses when they do it. Another piece that comes to mind is when somebody says: "I did it and I did it wrong. I did not understand Article 27 and Article 28 and now I am in trouble with the EPA and regulators". There is a genuine intent from our members to try to understand what this means and to put the best foot forward, but there is a fearfulness when it comes to engaging specifically with end-of-waste and by-product notifications that they will fall foul and then be in trouble. There is this dynamic in the process.

I will add a caveat to my statement about the EPA. All the industries know that there is a regulatory obligation and that Articles 27 and 28 are there to ensure there is no harm to human and ecosystem health. However, when I and the team in CIRCULÉIRE say to somebody, "Guess what? You can turn that production residue into a higher value application", the person just looks at me and says, "Oh great, where do I start? How do I do this?". I say, "You need to think about this and you need to speak to your enforcement officer". The nature of that relationship is changing with the circular economy programme in the EPA because the EPA is going to play a dual role, both as a regulator and also as a body to which industry can suggest an idea, ask whether it is good or bad, ask how to do it and how should it be done and so forth. My apologies for going off on a tangent, but one of the points in our submission to the Department of Environment, Climate and Communications consultation on the circular economy strategy and the commitment to streamline Articles 27 and 28 was that there is the example of other jurisdictions that have created help desks where, effectively, industry can come in free of charge, say it has this thing that it is trying to do and ask for some guidance. We do not have the full picture yet of how the Department and the EPA are proposing to streamline that process, but those types of supports which help business to meet the regulatory requirements and the targets can help to leverage the willingness that we see in CIRCULÉIRE with regard to embracing this model.

I apologise if I have not been able to address all the Senator's questions.