New study reveals what makes waste management systems work best for recycling
EU rules designed to improve the collection, sorting and recycling of packaging work best when producer fees are smarter, not simply higher, a new study reveals.
Extended Producer Responsibility (EPR) schemes require producers to contribute to the costs of managing packaging waste at end of life. Across the EU, these systems play a central role in financing collection, sorting and recycling infrastructure.
EPR systems lead to more effective recycling when they are transparent, well governed and data-driven, and when they differentiate fees by packaging material rather than lumping them together. These are among key findings of the study commissioned by EU packaging association EUROPEN and conducted across all 27 EU countries by Veolia’s CIRCPACK research unit. The research also shows that systems which differentiate fees according to packaging material tend to be more effective than those applying a single fee structure across different materials.
As Member States and economic operators prepare to implement the Packaging and Packaging Waste Regulation (PPWR), the study identifies the factors that distinguish EPR systems already on track to meet the PPWR recycling targets for 2030 and 2035 from those that are lagging behind.
Drawing on Eurostat data, Producer Responsibility Organisation (PRO) reports, national waste registries and format-specific recycling datasets, the analysis is structured around four key pillars: minimising material losses, circular reporting and monitoring, creating circular markets, and transparency. The findings are further illustrated through five country case studies: Belgium, Italy, Spain, Germany, Hungary.
The findings reveal that system design, governance, and transparency play a far greater role in driving recycling performance than the overall level of producer fees or EPR system models.
“The study demonstrates that the strongest-performing EPR systems are those built on transparent governance, robust data and well-designed incentives. As the European Commission prepares the Circular Economy Act, these findings provide valuable evidence on the design features that can help strengthen EPR systems and improve recycling performance across the EU,” said Francesca Stevens, Secretary General of EUROPEN.
Fee structure, not fee level, drives recycling performance
One of the study's clearest findings is that the structure of EPR fees matters more than their absolute level. Countries using granular eco-modulated fees that differentiate between packaging materials, formats and recyclability consistently outperform systems relying on flat or basic weight-based fees.
According to the study, Member States operating advanced, format-specific fee structures achieve significantly higher packaging recycling rates. At the same time, the report finds that increasing fees alone is unlikely to improve recycling performance unless revenues are transparently directed towards collection, sorting, and recycling infrastructure.
Infrastructural barriers hinder recycling at scale
While well-designed EPR systems can improve recycling performance, the study concludes that infrastructure remains a major barrier to achieving the PPWR's recyclability-at-scale requirements.
Flexible plastics, composite beverage cartons and several other packaging streams continue to face significant collection, sorting and reprocessing challenges across Europe. The report finds that no packaging category is currently on track to meet recyclability-at-scale requirements across all 27 Member States.
Achieving the PPWR's 2035 recycling at scale objectives will therefore require substantial investment in waste management infrastructure alongside improvements in packaging design and EPR governance.
Governance quality matters more than governance model
The study finds that not one EPR governance model is inherently superior. Instead, it finds that strong governance can deliver results regardless of whether a system operates through a single PRO or multiple competing PROs. Clear regulatory frameworks, transparent reporting and effective oversight are what matters and delivers results.
Data granularity is a key driver of EPR performance
Transparency and reporting quality emerge as another major success factor. Member States with detailed, publicly available reporting systems and format-level data achieve substantially higher recycling rates than countries relying on more aggregated reporting approaches.
The report highlights the importance of the PPWR's enhanced reporting requirements, while noting that significant gaps remain in data infrastructure and methodology harmonisation across the EU.
Financial transparency stops at the Producer Responsibility Organisation
While the Waste Framework Directive requires PROs to publish their fee schedule, scheme ownership and membership, and the procedure used to select waste-management operators, it does not require disclosure of how aggregate fee revenue is allocated downstream once it leaves the PRO. This downstream opacity is where most fee revenue is spent, and the study identifies it as the single largest visible gap in the current EPR transparency framework.
A roadmap for achieving PPWR targets
The study concludes that the highest-performing EPR systems share four common characteristics:
- Transparent methodologies and governance
- Consolidated operational responsibility
- Granular eco-modulated fee structures
- Format-level data collection and reporting
These design features, rather than higher spending alone, provide a practical roadmap to meet the PPWR's recycling objectives for 2030 and 2035.
With the upcoming Circular Economy Act expected to shape the next phase of EU waste and resource policy, the report highlights an opportunity to further strengthen EPR governance, transparency and reporting requirements across Europe.