Extended Producer Responsibility

At a glance

Extended Producer Responsibility (EPR) is a policy tool that extends the producer’s financial and/or operational responsibility for a product to include the management of the post-consumer stage, in order to help meet national or EU recycling and recovery targets. EPR policies thus generally shift the waste management cost or physical collection partially or fully from local governments to producers.

Packaging and extended producer responsibility

The Packaging and Packaging Waste Directive requires Member States to set up systems for the return and/or collection and reuse or recovery (including recycling) of used packaging from the consumer in order to meet the EU recycling targets. Thus, the EU imposes the legal obligation of meeting the recovery and recycling targets on Member States. However, national governments may, and often do, delegate this legal obligation to producers/importers through the setting of EPR schemes. 

EUROPEN has long been a strong advocate of Extended Producer Responsibility (EPR) schemes as an essential component of waste management in Europe. 

Recent legislative developments have introduced important requirements to ensure greater harmonisation and better enforcement of EPR schemes across the EU. While today most but not all Member States have EPR systems in place, the Packaging and Packaging Waste Directive obliges all Member States to set EPR schemes for packaging by 31 December 2024. Once in force, the PPWR will introduce an EPR registry and the eco-modulation of EPR fees based on the recyclability (at scale) of packaging and recycled content (the latter voluntarily). The Waste Framework Directive includes general minimum requirements to improve harmonisation, increase transparency, cost-efficiency, accountability and better enforcement of EPR obligations at national level. Under the new rules, eco-modulation of EPR fees has become mandatory with a view to boost recyclability. 

 

Our position

The adoption of EU-wide mandatory minimum requirements in the revised Waste Framework Directive is an important step to ensure greater harmonisation across EPR schemes, strengthen transparency and enforcement and drive investments into collection and recycling. 

In this context, EUROPEN supports the eco-modulation of EPR fees and the beneficial outcomes stemming from its conception. Nevertheless, it would have been interesting to have a broader revision of the WFD (the current one focuses on food and textile waste) that would have encouraged a better implementation of the minimum requirements of the EPR.  

At the same time, it is pertinent to note a concerning trend gaining traction in which Member States seek to increasingly take more control over the EPR systems, pushing for a shift towards a State-run EPR model. This phenomenon does not only undermine the objective of improving packaging waste management, it can also hinder the transparency and harmonisation of EPR systems.