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5. Implement­ation of EPR in the Nordic countries

EPR schemes are implemented across countries using various policy instruments, including product take-back requirements and economic tools like recycling fees, or a combination of these approaches (IEEP, 2017). Walls (2006) highlights four of the most common EPR policy instruments that make producers financially or physically (as per Lindhqvist’s definition) responsible for the environmental impact of their products at the end-of-life stage.
  • “Product take-back mandate and recycling rate targets.
    • Government mandates that manufacturers and/or retailers take back products at the end of the products' useful lives, in combination with recycling or waste diversion targets that producers are required to meet.
  • Product take-back mandate and recycling rate targets, with a tradable recycling credit scheme
    • Similar to the first approach but the targets apply to the whole industry, allowing firms to trade recycling credits among themselves.
  • Voluntary product take-back with recycling rate targets
    • Firms within an industry voluntarily organize a take-back system for their products and set recycling goals, without government mandates or penalties for non-compliance.
  • Advanced recycling fees (ARF)
    • A tax assessed on product sales, often used to cover recycling costs.
    • ARFs can be determined per unit or by weight, and they may be visible to consumers or assessed upstream on producers.” (Walls, 2006)
This variety of organizational models, levels of responsibility and policy instruments reflects different EPR practices across countries. Due to this variation, from specific requirements to target-oriented approaches, the EU has implemented minimum requirements to harmonize EPR schemes and to ensure fair competition among actors. (Deloitte, 2020)
 
Sweden
Finland
Norway
Iceland
Denmark
Packaging
1994
1997
1995
2005
In progress (2025)
Single-use plastic
2022
In progress (2023)
In progress
2023
In progress (2023)
Table 1. Year of implementation of producer responsibility for packaging and single-use plastic products in the Nordic countries.
As shown in Table 1, the concept of producer responsibility for packaging has long been established in several Nordic countries. The exception is Denmark, which is currently in the process of implementing such a system. On the other hand, producer responsibility for single-use plastics is relatively new and is either in the process of implementation or has recently been introduced. The following provides an overview of how these two EPR systems, primarily focusing on packaging, have been implemented across the Nordic countries, including recent or upcoming changes in regulations, as well as outlining some of the barriers and success factors. The information presented is based on the conducted interviews and relevant literature sources.

5.1 Sweden

EPR implementation

EPR schemes have been established for a range of product categories in Sweden, including packaging, electrical and electronic equipment (EEE), batteries, tires, end-of-life vehicles, pharmaceuticals, single-use plastics (such as fishing gear, certain tobacco products and filters, wet wipes, and balloons).
The extended producer responsibility applies to those producers that professionally manufacture packaging in Sweden or import packaging or packaged products to Sweden. Even businesses selling packaged goods to final users in Sweden from another country are subject to these regulations, although enforcement can be challenging.
Packaging producers in Sweden bear financial responsibility and are obligated to ensure the existence of collection systems. Producers are also responsible for developing products that are more resource-efficient, recyclable and do not contain environmentally hazardous or harmful substances. Furthermore, they are obliged to report data to the Swedish Environmental Protection Agency (SEPA) on the amount of packaging they place on the market, how much packaging that is collected as waste, and how the waste has been treated to follow-up the national and European recycling targets (Naturvårdsverket, 2022).
As the operational supervisory authority, the SEPA is responsible for ensuring that each producer fulfills their producer responsibility. This includes scrutinizing information from producers and ensuring compliance with the regulations regarding producer responsibility. Also, producers that supply a minimum of 1 ton of packaging per year on the market in Sweden must pay a supervisory fee to the SEPA. With the introduction of the Single-Use Plastics Directive, regulations on littering fees for certain products will be introduced.
Regarding plastic packaging, the two current Swedish collection systems for packaging, FTI and TMR, have both introduced differentiated fees for paper and plastic packaging since a few years, where fee levels correspond to recyclability. The packaging fee for plastic household packaging in 2023 is 5.52 SEK/kg or 8.56 SEK/kg depending on if the packaging is designed for recycling or not. The aim of the differentiated packaging fees is to reflect the actual cost of recycling. TMR also works to create incentives in the fee pricing for producers to choose and develop more recyclable packaging (Hammar, ., 2021). Unlike FTI, however, they are not transparent in presenting their fees. From January 2023, there are new legal requirements on transparent fees and mandatory differentiation of packaging fees for paper and plastic packaging. (Naturvårdsverket, 2023a) However, the design requirements set by the producer responsibility organizations themselves are much more detailed than the minimum requirements set up by SEPA. (FTI, n.d.)
Sweden’s recycling statistics for packaging for 2021 show that four of nine national recycling targets were met, for paper and cardboard, ferrous metal, aluminum, and aluminum deposit cans. However, Sweden, like many countries, faces difficulties in meeting its plastic recycling targets due to the diverse nature of plastics requiring various recycling processes. The recycling rate for plastic (including deposit PET bottles) is currently 33% and hence, does not reach the target of 50%. (Naturvårdsverket, 2022). The recycling rate for plastic packaging excluding PET bottles was 18.1% in 2021 and 19.3% in 2022 (svensk plaståtervinning, 2023).

Changes/new regulation

As the current ordinance on the EPR packaging scheme was replaced in 2023, there are several changes and new roles for producers and municipalities. A significant change is that, starting from 2024, municipalities will take on the operational responsibility of providing collection services for household packaging (Naturvårdsverket, 2023b). This will simplify the sorting process for residents, allowing them to sort their waste at home rather than having to visit a collection station. The change is expected to contribute to a larger share of recycled waste, a more resource efficient waste handling and decrease the need for new raw material, resulting in reduced CO2 emissions. The municipalities are also given responsibility for informing households about preventive measures and sorting of packaging waste.
From 1 January 2026, the municipalities must also collect packaging waste in squares, parks and in other popular places outdoors, and from 2027, all municipalities must have introduced close-to-property collection from households of waste from packaging in the materials paper, plastic, metal, and glass (Naturvårdsverket, 2020).
The new regulation also affects the producers. Previously, they were required to be affiliated with a suitable collection system but from 1 November 2023, the producers must instead be affiliated with an approved producer responsibility organization (PRO). The PROs are the ones receiving the waste from the municipalities, being responsible for the treatment process. However, the producers will keep the financial responsibility for collection and pay both for the municipalities management of household packaging and PRO’s waste handling. This shift of responsibility to municipalities to handle household collection will likely result in increased costs for the producers.
In 2021, the single-use plastics directive was implemented into Swedish legislation and was applied from 1 January 2022 (Naturvårdsverket, 2023c). The directive implies extended producer responsibility for certain single-use plastic products, including tobacco products with filter, balloons, wet wipes, and fishing gear that contains plastic. Consequently, starting from 1 January 2023, a littering fee regulation is in effect (Naturvårdsverket, 2023d). The fees, consisting of both a variable product fee and a fixed annual fee, fall upon those who place single-use products on the Swedish market. The fees are paid retroactively, with the annual fee being applicable from 2023 for most products and the product fee from 2024. However, for balloons and wet wipes, both fees will commence in 2025. The annual fee is intended to cover the SEPA’s expenses, while the product fee compensates municipalities for waste management related to those products.

Barriers/success factors

In Sweden, people are used to sorting their packaging waste due to the long-standing presence of producer responsibility. The system can be considered successful in certain aspects, while there are some challenges, which will hopefully be improved with the new regulation (2022:1274). Overall, there is a high level of trust between Swedish producers and PROs as well as in the recycling system itself from the public in that waste is recycled and not landfilled. PROs also have close collaboration/cooperation with each other and with municipalities. In a collective system like the EPR schemes, the fact that the PROs today operate as non-profits is said to ensure transparency for the individual producers. (Naturvårdsverket, 2020)
However, just as in other countries, the system faces the problem of free riders who consciously or unconsciously do not take their producer responsibility. It could be either ignorance of their responsibility or the belief that they will not face consequences for non-compliance.
The Swedish EPR schemes are generally clear both in terms of legislation and in the division of roles and responsibilities, which is said to lead to a high willingness of producers to fulfill their obligations. (Naturvårdsverket, 2020) However, due to vague requirements regarding packaging design at present, enforcing these requirements can be difficult and may require additional resources.
The deposit system stands out for its effective performance, primarily because it deals with a limited range of products, enforces strict guidelines on product design, and provides clear directions for item returns. This leads to an effective separation of waste streams, contributing to high-quality material recycling, emphasizing the importance of cleaner material flows to achieve increased circularity. This is reiterated in a report by the SEPA (2020) where it is also highlighted that there is a strong domestic demand from the manufacturing sector, which also has the capacity to process the collected plastics.
A similar effectiveness is observed in the voluntary producer responsibility for silage plastic (SvepRetur) primarily due to its simplicity, involving only one product, fewer involved actors, and a clear, clean material flow.

5.2 Finland

EPR implementation

Within Finland, the concept of producer responsibility covers several product categories including batteries and accumulators, vehicles, packaging, paper and paper products, tires, and electrical and electronic equipment
The province of Åland operates its own system for producer responsibility, but this is not examined further within the scope of this report.
.
The responsibility associated with packaging lies with individual producers, such as Finnish packagers or importers. An interesting development since 2021 is the extension of this responsibility to distance sellers who directly sell to end-users. This means that even major platforms like Amazon would need to align with a Finnish Producer Responsibility Organization (PRO), as the European directive says that each country must include the responsibility of distance sellers in their legislation. However, the enforcement of this becomes challenging because these companies are outside the Finnish jurisdiction.
Producer responsibility covers the collection, transportation, and waste management, including recycling. The associated costs are covered by recycling fees paid by producers. These fees vary based on the product category. PROs have the responsibility of organizing waste collection and recycling efforts. Each PRO determines its fees based on its estimated expenses, ensuring they operate as non-profit entities and do not exceed actual costs.
At the start of each year, producers must report their product quantities to RINKI, a service company working for the PROs, and the fee they pay (EUR/kilo) is determined using the previous year's data. Fee levels differ between consumers and businesses (B2B) for packaging, with B2B fees generally lower due to a less complex collection system. Material composition also influences fee levels, with initial steps taken toward modulated fees, primarily tied to material recyclability. In 2022, the recycling fee for consumer packaging for plastic was 0.18 EUR/kilo. In 2023, the recycling fee has been raised to between 0.27 EUR/kilo and 0.395 EUR/kilo depending on the plastic material (RINKI, n.d.).
To ensure compliance, the Pirkanmaa ELY Centre, that works closely to the Ministry of Environment, holds the responsibility of overseeing and conducting regular monitoring of producer responsibility. PROs are mandated to meet legislative targets. If these targets are not met, the ELY-center can inquire about improvement plans, although no sanctions are imposed.
The challenge of meeting targets becomes more apparent in plastics, where despite progress, new reporting rules, applicable to all EU countries, have led to a significant drop in the recycling rate. While previous calculations indicated a 45% recycling rate for plastic, the application of new rules resulted in a rate of 29% in 2021. Similar trends of declining recycling rates are also seen in other countries due to the new reporting rules.

Changes/new regulation

Notably, there has been a shift in the criteria for who bears producer responsibility. Previously, it was only applicable to those with turnovers exceeding EUR 1 million. Starting in 2024, this requirement will extend to all producers, irrespective of their turnover.
Finland is in the process of implementing the SUP directive where new obligations for companies with producer responsibility include paying a SUP fee and informing consumers. The 2023 costs are covered by a SUP fee which is invoiced from the companies in 2024 and varies by product group.
The SUP directive also increases the reporting obligations of producers when data on SUP products put on the market per SUP product group are needed for monitoring the SUP requirements. The separate packaging reporting as part of the regular packaging data reporting begins in 2024 when packaging data for 2023 is reported. (RINKI, 2022)

Barriers/success factors

The fee for packaging has been increasing in the last few years and will increase even more with the SUP directive. This poses a significant issue for the producers and could potentially affect the attitudes of the entire system. For instance, local decision-makers now seem to value low waste fees instead of improvements of the waste collection services that instead could increase costs (Salmenperä, 2021). Additionally, the new reporting rules from the EU directive have intensified the workload, as now reporting is required for various materials and categories.
The cost increase presents a dilemma, particularly in encouraging more producers to join a PRO. However, PROs lack the authority to enforce participation, leading to a percentage of "free riders," estimated at around 15%. With the removal of the turnover requirement, more companies may join PROs from 2024, although their size may only represent around 5% of the market volume. A majority of the market's influence is held by about 10% of responsible producers.
An advantage that has been highlighted is that the system is structured to be producer-driven, where PROs can only be initiated by producers and must operate on a non-profit basis. This arrangement empowers producers by providing them with obligations and authority within the system.

5.3 Norway

EPR implementation

EPR has been an important environmental policy instrument since the mid-1990s in Norway. Today, Norway has extended producer responsibility for electrical and electronic waste, discarded vehicles, tires, batteries, packaging (including beverage packaging), and insulated glass panes containing PCBs.
Regarding packaging, companies that produce or import a minimum of 1 000 kg of a packaging type are required to participate in a return scheme and become members of an approved recycling company. This obligation also extends to companies that import goods with packaging (Miljødirektoratet, 2023a). Through their membership, the companies contribute financially to the collection, sorting, material recycling and other treatment of used packaging and packaging waste. In 2021, approximately 28% of plastic packaging from Norwegian households and businesses was recycled.

Changes/new regulation (proposals)

In 2020, the Norwegian Ministry of Climate and Environment (Klima- og miljødepartementet, KLD) commissioned the Norwegian Environment Agency (Miljødirektoratet) to review and propose improvements to the extended producer responsibility systems. The assignment has been divided into a three-part mission, with the first two sub-missions already reported (Miljødirektoratet, 2022a).
In the first part of the assignment, challenges with the current system were identified, along with the need for changes to ensure compliance with the minimum requirements of the EU’s waste directive. In part two, recommendations for how the systems can become more efficient, more robust, and better support a circular economy were suggested.
One key recommendation to clarify who has the obligation to be a member of an approved recycling company is to change the definition of who is a producer to “who professionally imports packaging or packaged products to the Norwegian market or in Norway manufactures packaging for the Norwegian market”. The recommended definition is expected to reduce the number of liable producers and consequently decrease instances of free riding. Another recommendation to identify free riders is to establish a producer register. It is also recommended to assess whether the 1 000 kg limit should be changed or possibly removed. Additionally, the compensation that the producers pay to the recycling companies is recommended to be differentiated to a greater extent.
Part three of the assignment, which is ongoing, focuses on proposing rule changes for producer responsibility for packaging in line with the recommendations from part two of the assignment. Key areas include financing the waste management of packaging (and beverage packaging), assessing the lower limit for producers’ obligation to be a member of an approved recycling company, refining the definition of a producer, mandating waste prevention reporting, and reducing the number of free riders.
The Norwegian Environmental Agency has additionally proposed two new schemes (Miljødirektoratet, 2022b). The first scheme targets plastic waste from fisheries, aquaculture, and recreational fishing. The second scheme aims to hold producers responsible for covering costs for waste management and cleaning up litter from single-use plastic products in public spaces. For the latter, the Norwegian Environment Agency has so far submitted a proposal for a regulation to the Ministry of Climate and Environment and are now waiting for response from the ministry before the proposal can be sent for consultation (Miljødirektoratet, 2023b). The Norwegian Pollution Control Act § 28 already contains a prohibition on littering and the basis of the regulation is that the litterer, the one who throws it away, should cover the cost of clean-up themselves (Lovdata, 2023). The littering ban is general, and therefore also applies to the single-use plastic products that end up as litter. However, it is only the municipality’s costs for cleaning up littering of the single-use plastic that must be covered by the producers within the extended producer responsibility for single-use plastic (Miljødirektoratet, 2023b).

Barriers/success factors

A Deloitte report (2020) has highlighted weaknesses within the current legal framework for EPR for plastics in Norway, aligning with the Norwegian Environment Agency’s findings. Among the identified issues are the unclear definition of the producer that is subject to the EPR obligations, limited cost coverage and transparency, and insufficient incentives for creating a circular value chain for plastic packaging within the current framework. In line with the recommendations from the Norwegian Environment Agency, Deloitte identified necessary changes, such as holding producers with the most influence on product design responsible for the products they put on the market and introducing requirements for modulating fees based on true lifecycle costs.

5.4 Iceland

EPR Implementation

Iceland has had an EPR scheme for plastic and paper packaging since 2005, and for all other packaging types since the 1st of January 2023. In addition, there are also EPR schemes for other materials. The EPR systems are operated by the Icelandic Recycling Fund (IRF), a government-owned agency established in 2003 that uses economic incentives to increase recycling. The fund charges manufacturers and importers with a recycling fee, directing these fees toward enhancing recycling efforts. The IRF’s board includes representatives from various stakeholders, including municipalities and producers, with the Ministry of Environment holding the decisive vote.
The EPR scheme implemented differs from those in other countries and is viewed as a valuable tool to enable higher recycling rates (Mager, Traxler, Fischer, & Finger, 2022). The system is set up so that producers and importers of specific products pay a recycling fee to the customs office, based on weight. The fee is collected to cover the cost of transport and recycling. The fee level is determined by the actual costs of waste management and the amount of waste collected, to accurately capture waste treatment expenses linked to the product rather than mirror the product’s environmental impact. This implies that when environmental ambitions change, i.e., the recycling targets, then the fee level changes. For instance, the fee for plastic packaging has recently been raised from 40 ISK per kilo to 82 ISK per kilo, as it now also includes separate collection. The fee level differs between different categories of products and is, for example, 42 ISK per kilo for paper packaging and 10 ISK per kilo for wood packaging.
From 1 January 2023, producers are also responsible for the costs of cleaning up plastic products when they have become litter as well as informing consumers and preventing waste. A fee of 27 ISK/kg is imposed on wet wipes, tobacco products with filter, balloons, and other single-use plastic products, all of which fall under the scope of extended producer responsibility (Úrvinnslusjóður, 2022).

Changes/new regulation

Initially, the focus of the system leaned more toward waste management than prevention, a perspective that was not incorporated into the fund system. Today initiatives are taken by the fund to increase public awareness to prevent waste. Municipalities play a central role in public awareness, being the key actor in the operative waste collection. Public awareness campaigns, often utilizing social media platforms and influencers, constitute the primary approach to achieve higher collection rates.

Barriers/Success factors

While the separate collection was relatively recently implemented, Iceland encountered challenges during the initial phase. The response so far has not been as positive as hoped, but there is optimism that these challenges will be progressively resolved.
Overall, the fund system is considered to have been relatively successful, not particularly controversial. Since it is mandatory for producers to pay the fee, either at the customs office when they import, or by reporting the amount they produce to the tax office, compliance is good. Thus, there is no problem with free riders.
The IRF’s overarching goal aligns with meeting the minimum requirements of the waste directive. Thus far, Iceland has met the targets for plastic recycling but is still striving to attain the target of 50% for 2025. However, a drawback of the fund system is the absence of penalties for not meeting the targets.
Another issue is the inflexible tariff codes that cannot be modified for customers. Currently, there is only one tariff, regardless of whether the material is environmentally friendly or not. These tariffs lack differentiation between sustainable and less sustainable resources. However, a significant fee modulation based on the products durability, reusability, dismantlability, and recyclability shall be implemented (Mager, Traxler, Fischer, & Finger, 2022).

5.5 Denmark

EPR implementation

In Denmark, there is currently no Extended Producer Responsibility (EPR) scheme in place for managing plastic packaging. However, EPR schemes for batteries, used vehicles, and WEEE have been implemented. Denmark' complies primarily to the packaging targets set by the EU through a national action plan for a circular economy, which consists of a national plan for the prevention and management of waste for 2020–2032. Furthermore, there is a political agreement on climate change relating to waste management, which includes initiatives to support increased recycling and thereby will support EU-targets on packaging waste.
The legal framework for waste management in Denmark is established by the Environmental Protection Act, with specific Statutory Orders governing packaging and packaging waste. In Denmark, municipalities have the general responsibility for waste management from households, whereas handling of business waste is generally privatized. Municipalities often collaborate on waste management through public companies. Denmark did not implement EPR schemes for packaging waste previously as other member states did because the existing municipal system was considered efficient. In fact, Denmark has already reached the 2025 EU recycling target for glass and wood packaging and in 2021, 23% of plastic packaging waste, 71% of fiber packaging waste and 66% of metal packaging waste was recycled.
In 2021, new legislation on waste collection was implemented, which streamlined municipal waste collection. All households are now required to sort waste into ten different waste types, including plastic. This means that recyclable packaging waste is generally mixed with recyclable non-packaging waste in the collection system. Municipalities are obliged to collect selected recyclables curbside, but there is also access to public recycling stations. Waste management costs are covered by a municipal waste fee paid by citizens, with a few exceptions. Littering is, for instance, financed through taxes. Businesses are obliged to sort waste in the same ten waste types as households, and they also have access to public recycling stations. Small businesses may use household collection systems provided by municipalities.
Denmark also employes a deposit-return system for a beverage packaging and refillable bottles. The deposit-return system has very high recycling rates and was recently expanded to include juice containers.
In Denmark waste handlers are obliged by law to report waste data to the national waste data system in Denmark (ADS), including the amount of waste collected. The data from ADS forms the basis for mandatory reports to Eurostat and national statistical reports of waste which are published annually. The latest report regarding packaging waste includes data from 2021. (Miljøstyrelsen, 2023)
Producer responsibility for tobacco product filters was implemented in the beginning of 2023 and was the first of eight product groups becoming subject to producer responsibility, and the producers now have the financial responsibility to pay for the cleaning up of this type of litter.  Moreover, the producer responsibility extends to marking and providing information on the product. Producers are also obliged to register with the Danish Producer Responsibility (DPA), report to the Danish Environmental Protection Agency as well as to pay a fee. From the 4th quarter of 2023, the fee is 0.0092 DKK per filter put on the Danish market.  
Most producers in Denmark use PROs, known as collective systems in Denmark, to fulfill their producer responsibility.

Changes/new regulation

In 2022, necessary adjustments for minimum requirements according to the WFD for WEEE and ELVs were made. Currently, Denmark is in the process of implementing EPR schemes for packaging and single-use plastic products (under the SUP Directive). This is expected to be fully implemented in 2025. From 2025, EPR for fishing equipment will also be implemented, but this will not entail a responsibility for cleaning up litter.
There is a widespread political consensus regarding the impending regulation for producer responsibility for packaging waste. In line with this, Denmark is expected to implement a hybrid model for EPR on packaging waste, where municipalities continue to collect waste from households while producers take over the organizational responsibility for waste treatment. For business waste, businesses will continue to be responsible for waste collection and treatment while producers will bear the financial responsibility. Administrative tasks such as the producer register and allocation of waste to producers or PROs will handle by a private non-profit organization, the Danish Producer Responsibility (DPA), established in 2005. The Danish Environmental Protection Agency will be responsible for guidance, oversight, and enforcement. Ultimately, there is an expectation that most producers will join PROs to fulfill their responsibilities and that there will be three or four competing PROs on packaging waste.
The Danish Parliament has decided that producer responsibility for packaging should lie with the person who has the most significant influence over packaging design, which is usually not the packaging manufacturer but the person who orders the packaged product. (European Union, 2022) However, prior to going into effect, the “producer” term needs to be defined more precisely at the executive level. In this regard, Denmark is also looking into current EU negotiations on a new packaging regulation, in which a common producer definition is on the table.

Barriers/success factors

Denmark has lower plastic packaging recycling rates compared to other Nordic countries, which may be due to the following reasons. Firstly, municipalities in Denmark have mainly collected plastic waste at local recycling stations, and not by the household (curbside), and the country is still waiting to see the full results of the streamlining of waste collection. Secondly, Denmark has relatively few sorting facilities for packaging waste, probably due to the country’s relatively small amount of waste compared to other EU countries. This may also explain the significant portion of Danish plastic waste exported to EU countries such as Germany.
According to the latest report regarding packaging, which includes data from 2021, Denmark exports about 21% of plastic packaging. (Miljøstyrelsen, 2023) The streamlining combined with producer responsibility is expected to result in greater and more uniform amounts of waste, which is expected to encourage companies to invest in sorting facilities in Denmark and result in increased recycling. There is currently a private sorting facility for plastics and metal waste under construction in Esbjerg, which is expected to open in 2025.  
As previously mentioned, Denmark has a specific deposit-refund scheme for beverage packaging and refillable bottles This deposit-refund scheme has been largely successful. (McKinsey & Company, 2019)
According to a 2019 report by McKinsey & Company, some key components of the DRS's success include:
  1. Producers registering cans and bottles with DRS for participation in the deposit refund system.
  2. Consumers returning used products, receiving a deposit refund, and ensuring that packaging is reused.
  3. Shops and restaurants being obligated to handle empty bottles and cans after sale, with support from DRS.
  4. DRS managing product registration, fee and refund handling, and collection and sorting.
  5. Reprocessing of recycling cans and bottles into new ones at facilities located abroad. (McKinsey & Company, 2019)