Brussels, 26 January 2025 – Extended Producer Responsibility (EPR) is a key part of the EU’s circular economy policy. It ensures that producers take responsibility for the end-of-life management of the products they place on the market.
In recent years, however, several Member States have started to introduce State-run Producer Responsibility Organisations (PROs). This trend is raising growing concerns among industry stakeholders.
Effective EPR systems are built on three core principles. They must be producer-driven, harmonised across the EU, and based on a clear separation of roles between regulator, supervisor and operator. These principles are set out in Article 8a of the Waste Framework Directive and are essential to ensure transparency, accountability and efficient waste management.
Some recent national initiatives risk weakening these foundations. When PRO functions are assigned to State-owned or State-controlled bodies, public authorities may act at the same time as regulator, supervisor and operator. This creates a risk of conflicts of interest.
Experience from other waste streams shows that such models can reduce transparency in the use of EPR fees. They may also weaken incentives to invest in collection, sorting and recycling infrastructure. In some cases, EPR fees risk being perceived as public revenue rather than as targeted funding to improve system performance.
Governance also matters for investment. Predictable and producer-led EPR systems provide the legal certainty needed to attract private investment. Where fee-setting or reinvestment rules are unclear, investment risks increase and long-term system costs may rise.
Producer-driven PROs also help link product design to end-of-life performance. Through eco-modulated fees, they can reward recyclability, durability and material efficiency. This creates clear incentives for innovation. More centralised or State-run models may simplify administration, but they risk weakening these incentives, especially in new EPR schemes such as textiles.
Finally, diverging national EPR models already create significant administrative burdens for companies operating across borders, particularly SMEs. Introducing State-run PROs at national level risks further fragmenting the Single Market at a time when industry is calling for greater EU-level alignment.
Industry organisations therefore urge European and national policymakers to ensure that EPR systems remain producer-driven, transparent and accountable. Clear separation of regulatory and operational roles, as well as the ring-fencing and reinvestment of EPR fees, are essential.
A predictable and harmonised EPR framework is key to supporting investment, competitiveness and the EU’s circular economy objectives.
Read the full statement.