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 (PPWD) established a requirement for 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 typically 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.
Over the years, legislative developments have introduced important requirements to ensure greater harmonisation and better enforcement of EPR schemes across the EU. The Packaging and Packaging Waste Directive, when revised in 2018, introduced an obligation for EU Member States to set up EPR schemes for all packaging by 31 December 2024. While EPR schemes for household packaging were established in most Member States, several countries only recently included industrial and commercial packaging in the scope of their schemes to meet this deadline.
The new Packaging and Packaging Waste Regulation, replacing the PPWD, entered into force on 11 February 2025 and will start applying from 12 August 2026. It mandates the introduction of national registers of producers to monitor compliance of producers with EPR requirements (Article 44), as well as the modulation of EPR fees on the basis of packaging recyclability performance grades (Article 6). General minimum requirements for extended producer responsibility schemes are included in Article 8a of the Waste Framework Directive and aim to improve harmonisation, increase transparency, cost-efficiency, accountability and better enforcement of EPR obligations at national level. Article 8a notably makes the modulation of EPR fees mandatory to boost recyclability.
Our position
EUROPEN has long been a strong advocate of well-functioning and efficient EU EPR schemes for packaging, as it is key to advance the European circular economy and will be crucial for the creation of an EU market for secondary raw materials.
The adoption of EU-wide mandatory minimum requirements in the Waste Framework Directive (WFD) was an important step to ensure greater harmonisation across EPR schemes, strengthen transparency and enforcement and drive investments into collection and recycling. However, despite Article 8a and the push for greater harmonisation introduced by existing and future EU legislation, key minimum requirements laid down in the WFD are not properly enforced and a plethora of schemes exists across the different EU Member States.
To improve the efficiency of EPR schemes for packaging, producer contributions must, amongst others, be streamlined towards the right infrastructures and ensure the effective recycling of packaging waste, for which the earmarking of fees will also be fundamental.
It is also 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.