Extended Producer Responsibility (EPR) has been a core element of EU waste and circular economy policy for over 30 years. While schemes have expanded to support objectives on circularity, competitiveness and resilience, their performance and governance vary across Member States, limiting value for money and the effective functioning of the internal market.
This report examines how EPR schemes are governed across the EU and whether current legislation ensures transparency, accountability and fairness. Using packaging EPR as an example, it shows these challenges are systemic and highlights the need for more consistent EU-level requirements.
Guidance alone is insufficient. The report therefore proposes targeted amendments to the Waste Framework Directive (WFD) through the Circular Economy Act (CEA), supported by implementing acts, to establish common EU requirements for transparency, auditing, monitoring, enforcement, penalties, and harmonised registration and reporting.
Related resources
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Position paper: Reforming EPR through the Circular Economy Act
This position paper calls for governance reform focused on transparency, monitoring, audits, and penalties to ensure EPR systems deliver credible environmental outcomes, fair cost allocation, and a functioning internal market.