New study shows what must be fixed to close Europe’s recycling gap
As the European Commission prepares its upcoming Circular Economy Act (CEA), it should start from a simple reality: Europe will not build a strong market for secondary raw materials on fragmented waste management systems.
That is the central message reinforced by CIRCPACK by Veolia’s new study assessing EPR systems performance in the European Union, commissioned by EUROPEN and officially released on 18 June 2026. Looking across all 27 Member States, the study shows that performance gaps between national packaging EPR systems remain wide, and that these gaps are not accidental. They reflect concrete differences in system design, governance, transparency and infrastructure.
These findings matter. The Packaging and Packaging Waste Regulation (PPWR) has now set binding recycling targets and harmonised reporting requirements across the EU, making the ability of packaging to meet recyclability at scale requirements a condition for continued access to the Union market. But whether those targets are met in practice will depend on whether national EPR systems are capable of delivering effective collection, sorting and recycling at scale.
The study points to a simple conclusion: better results come from better system design.
- First, the study shows that governance quality matters more than governance model. High-performing systems are not defined by whether they are single-PRO or competitive multi-PRO. What matters is whether responsibilities are clear, oversight is strong, reporting is robust and financial flows can be tracked through the system. In other words, results depend less on institutional labels than on whether the framework is designed to deliver accountability and performance.
- Second, the study underlines that data granularity and transparency are essential. Member States with more granular, publicly available and verifiable reporting perform better. Better data makes it possible to identify where material is being lost, where investment is needed, and whether fees are being used effectively. Without comparable and transparent data, weak performance remains hidden and corrective action becomes much harder.
- Third, the study confirms that Europe faces a very practical obstacle: infrastructure gaps remain a major barrier to recycling at scale. For several packaging formats, sorting and reprocessing capacity is still insufficient across much of the EU. This means that circularity will not be achieved through targets alone. It requires investment in the systems that make collection, sorting and recycling possible in practice.
- Finally, the strongest driver of performance is not the overall level of EPR fees, but how those fees are structured. Systems with granular, eco-modulated fee structures - differentiating by material, format and recyclability - perform significantly better than systems relying on flat or basic fee models.
These findings should directly inform the preparation of the CEA.
The CEA should help move Europe beyond fragmented national approaches by establishing a more harmonised and effective framework for EPR, through a dedicated EU EPR Regulation. It should strengthen governance and transparency, support more comparable and granular reporting, promote eco-modulation, and help ensure that producer contributions are directed to the collection, sorting and recycling infrastructure needed to meet Europe’s circularity objectives.
Just as importantly, it should recognise a basic principle: EPR must remain focused on its core purpose - organising and financing effective waste management, and deliver EU’s recycling objectives. If Europe wants a genuine market for secondary raw materials, it needs systems that perform on the ground.
CIRCPACK’s new study makes one point unmistakably clear: the best-performing systems already show what works. The challenge now is to translate that evidence into an EU framework capable of lifting performance across all Member States. The Circular Economy Act is the opportunity to do exactly that.
WHAT DID YOU MISS?
- 18 June 2026: Publication of CIRCPACK by Veolia’s study on EPR system performance in the European Union.
WHAT'S NEXT?
- Q3 2026 (TBC): Expected publication of the European Commission’s proposal for a Circular Economy Act.