Circular Economy: Major industries call for common EU minimum requirements for Extended Producer Responsibility schemes in Europe

27 October 2015

Common waste stream views on EPR in Europe

Brussels, 27 October 2015 – Major manufacturing industry sectors in Europe that fall under the legal obligations of Extended Producer Responsibility (EPR)*, i.e., packaging, batteries, WEEE and tyres respectively represented by EUROPEN, EPBA, LightingEurope and ETRMA, call for common binding EU minimum performance requirements for EPR schemes in the legislative part of the Circular Economy Package due to be published by end 2015. These recommendations have additionally been endorsed by AIM, the European Brands Association.

A strengthened EU regulatory framework for EPR aims to support EPR obligated industries and the Member States that apply EPR as an end-of-life tool to help reach related national and EU targets. Improved implementation, enforcement, accountability of all actors involved in EPR implementation, along with EU minimum performance requirements (see attached) will help ensure a level playing field for all EPR schemes and promote a viable market for secondary raw materials. In view of the forthcoming Circular Economy proposal, the co-signatories seek to correct market failures by calling for a strengthened EPR regulatory framework in EU legislation.

Our common requirements are valid across the different waste streams and EPR compliance models in Europe.” said Virginia Janssens, Managing Director of EUROPEN. “However, where appropriate, these common rules will need to be complemented with sector specific EPR legislation addressing our specific market challenges and supply chains structures. For instance, EPR and its implementation will also need to be embedded in the Packaging and Packaging Waste Directive, respecting the lifecycle approach and the Internal Market principle”, Ms Janssens stressed.

Hans Craen, Secretary General of EPBA, states that “in particular in light of the current discussions on circular economy, it is an opportune moment to discuss and move forward with common EU minimum requirements for extended producer responsibility.” He added that “these common minimum requirements for EPR will form a good basis for Member States in implementing a more coherent producer responsibility framework for the collection of portable batteries”.

Transparent and accurate reporting of EPR schemes is necessary to ensure non-discrimination, cost efficiency and flexibility”, said Fazilet CINARALP, Secretary General of ETRMA. “This includes transparency of material flows, costs, tendering procedures, geographical scope and overall financial solidity. For transparency reasons, the environmental fee paid when buying a new tyre should be visible to the buyer as separate line item on their invoice and be reflected through the entire supply chain”. She further stressed that “consumer engagement and participation is a pre-requisite to the success of any EPR scheme. In the case of tyres, this should not only cover consumers but also professionals that are mounting and dismounting the tyre.

"LightingEurope believes that EPR can be a very effective way of enhancing a more circular approach. But, without consistent implementation, ‎environmental outcomes are diminished, and a level playing field is compromised." stated Zoltan Pilter, Chair of the association's collection and recycling working group.

Additional and individual waste stream positions on EPR and/or the Circular Economy can be found on the respective websites of the co-signatories.


* Extended producer responsibility means the producer’s full or partial operational and/or financial responsibility for a product extended to the post-consumer state of a product’s life cycle, as a means for Member States to meet EU collection, recycling and/or recovery targets.

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Signed by the following industry organisations:

  • EUROPEN  - the European Organization for packaging and the Environment

EUROPEN -- the European Organization for packaging and the Environment -- is an EU industry association in Brussels presenting the opinion of the packaging supply chain in Europe on issues related to packaging and the environment, without favouring any specific material or system. EUROPEN members are comprised of multinational corporate companies spanning the packaging value chain (raw material producers, converters and brand owners) plus six national packaging organizations all committed to continuously improving the environmental performances of packaged products, in collaboration with their suppliers and customers. www.europen-packaging.eu

EUROPEN’s Factsheet on EPR for used packaging can be consulted here.

  • ETRMA  - European Tyre & Rubber manufacturers' association

Established in 1959, ETRMA is devoted to advocating the interests of the tyre and rubber manufacturing industries with the European Union Institutions and other international organizations. ETRMA contributes to ensuring the development, competitiveness and growth of the tyre and rubber industry in contributing to all the initiatives in favour of health, safety & environment protection, transport and road safety and access to third markets in coordination with the European public authorities. The Association represents 4,200 companies, which employ directly 360 000 people in the EU. All together they generate a turnover exceeding € 49 billion. The product portfolio of our members is extensive ranging from tyres (all vehicle types), other automotive and construction rubber products to pharmaceutical, baby care, food contact applications, etc.

Additional information at www.etrma.org & www.etrma.org/tyres/ELTs/ELT-management/producer-responsibility

  • EPBA  -The European Portable Battery Association

EPBA -- The European Portable Battery Association (EPBA) is the authoritative voice of the portable power industry. The association supports the common interests of its members regarding portable batteries and battery chargers with European institutions and other leading international bodies to provide consumers with complete power solutions which are sustainable across their life-cycle. The members of EPBA are manufacturers of portable batteries, as well as National Associations and Original Equipment Manufacturers (OEMs).
Additional information available at www.epbaeurope.net

  • LightingEurope  - The voice of the lighting industry

LightingEurope is an industry association representing leading European lighting manufacturers, national lighting associations and companies producing materials. We are committed to innovation, sustainability, quality and leadership. We contribute to shape policy and establish industry standards and guidelines. We are dedicated to promoting efficient lighting practices for the benefit of the global environment, human comfort and the health and safety of consumers.

Additional information available at www.lightingeurope.org

  • AIM  - European Brands Association

AIM is the European Brands Association.  AIM’s membership comprises corporate members and national associations that have a similar but more local constituency. Altogether, AIM represents directly or indirectly some 1,800 companies ranging from SMEs to multinationals, accounting for some €450bn  sales and two million jobs in Europe alone. Members are primarily manufacturers of branded products in fast moving consumer goods. They are united in their purpose to build strong, evocative brands and as such place the consumer at the heart of what they do.

Additional information available at www.aim.be