While the explanatory memorandum of the draft states that this measure is necessary because "public packaging containers are often used to dispose of waste that does not belong there," it does not convincingly justify, so far as the justice ministry is concerned, why surveillance cameras are the best solution or how they would effectively address the problem.

The Ministry of Justice has pointed out that the draft fails to demonstrate that the desired goal—reducing improper waste disposal—will be achieved. The ministry has argued that the bill's "explanatory memorandum does not justify the necessity of the measure nor convincingly demonstrate that the desired goal will be achieved."

The justice ministry also raised privacy concerns, stating that the bill in its current form does not clarify who would process the footage from the cameras, an issue which could lead to legal and procedural complications. "It remains unclear who would process these violations," the ministry argued.

The Ministry of Justice concludes that "this proposed amendment must be removed from the bill," for the reason that it does not provide a clear or convincing case for the necessity of surveillance or its potential effectiveness.

The draft amendment to the Waste Act and Packaging Act, sent for approval by the Ministry of Climate in November, aims to strengthen the role of local governments in organizing a competitive waste market. It also incorporates the plan to start monitoring garbage containers more carefully via surveillance cameras as noted above.

The bill stipulates that photographic or video material obtained during monitoring would be used to identify persons who have placed inappropriate waste in or around a public packaging container and possibly as evidence of the commission of an offence.

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