Transforming EPR: The future of circular packaging
Extended Producer Responsibility (EPR) is a cornerstone of EU waste management and a key lever to achieve the EU circular economy goals. Yet, today’s waste management landscape across the EU remains extremely fragmented, marked by uneven performance and divergent national regulatory frameworks. Nearly half of all EU countries still landfill more than 30% of their municipal waste, with four touching peaks between 60% and 80%. When it comes to recycling, only nine Member States are expected to meet the 2025 recycling target. These shortcomings must be tackled head-on in order to achieve a truly circular economy in Europe, establish a robust EU market for secondary raw materials and create the enabling conditions needed to meet the sustainability requirements set forth at EU level, for instance as part of the EU Packaging and Packaging Waste Regulation (PPWR).
EPR talks
On 12 November, EUROPEN hosted a workshop in Brussels, “Transforming EPR: The Future of Circular Packaging in Europe”, gathering 190 guests and experts in the field to discuss those issues: obligated industry representatives, Producer Responsibility Organisations, waste management operators, EU and national decision-makers, and more. The conclusion was clear: EPR is pivotal to boosting packaging circularity, but greater harmonisation, transparency and collaboration remain necessary to ensure the schemes’ efficiency, at a sustainable cost.
CEA loading
This event was the first of a series of dialogues that will be very much needed in the preparation of the upcoming Circular Economy Act (CEA). In EUROPEN’s view, the upcoming CEA represents a unique opportunity to address the structural deficiencies currently present in (packaging) waste management across Europe, establish a robust EU market for secondary raw materials and create the enabling conditions needed to meet the sustainability requirements set forth at EU level.
The EU Commission has already taken several preparatory steps for the future CEA, which is expected to be adopted in Q3 2026 (TBC). In August 2025, it launched a public consultation and Call for Evidence, with feedback open until 6 November 2025. A four-week targeted stakeholder consultation was also held in November to collect detailed evidence on specific topics, including (non-exhaustive): by-products and End-of-Waste criteria, Extended Producer Responsibility schemes, improving waste management systems, enhancing the recovery and valorisation of scrap metals and critical raw materials, landfilling and bottom ash recovery, bio-waste, recycled and biobased material content targets for specific products, trans-regional circularity hubs, and applying the polluter-pays principle for waste containing PFAS.
The CEA has the potential to bring actionable solutions to fully leverage the potential of Europe’s waste management system, notably:
- To enhance harmonisation and address gold-plating, by ensuring the future CEA is grounded in an internal market legal basis (Article 114 TFEU) and exploring the creation of a horizontal, directly applicable EU EPR Regulation;
- To strengthen and harmonise EPR schemes’ governance;
- To increase EPR’s schemes cost efficiency and transparency, supported by the earmarking of EPR fees and use of net cost principle;
- To lighten administrative burden, via the creation of a one-stop-shop for information, registration and reporting;
- To ensure the free movement of packaging waste, enabling the creation of a Single Market for secondary raw materials.
The New CEA should also clearly exclude State-run EPR systems from EU legislation. Although still limited in the EU, this approach is gaining attention. Poland has already moved in this direction through a draft legislation seeking to transform its current EPR framework into a State-run system, and a proposed amendment to the Environmental Fund Act in Slovakia is raising serious concerns for the packaging value chain.
WHAT DID YOU MISS?
1st August - 6 November 2025: CEA public consultation
6 November – 4 December 2025: Targeted stakeholder consultation on the CEA
12 November 2025: EUROPEN “Transforming EPR” workshop
WHAT'S NEXT?
September 2026 (TBC): Publication of the New Circular Economy Act