A coalition of prominent European industry organisations, including EURATEX and Eurocommerce, has issued a joint statement urging the development of a strong, unified legislative framework for Extended Producer Responsibility across the European Union. The statement calls on the relevant EU legislative authority to move Europe away from fragmented waste management practices and towards a properly functioning internal market for secondary raw materials.
Extended Producer Responsibility, commonly known as EPR, is already used across the EU to finance waste collection, sorting and recycling activities. However, the coalition has pointed out that performance under existing EPR systems remains uneven between member states, with divergent national rules continuing to limit the overall effectiveness of these schemes.
The Case for a Harmonised EPR Regulation
The industry groups are calling for a directly applicable EU regulation that would cover EU-mandated EPR schemes and the relevant waste streams, with sector-specific requirements introduced where necessary. According to the joint statement, establishing common rules across member states would reduce regulatory fragmentation, support cross-border value chains and offer greater legal certainty for companies operating circular business models.
The proposed EU EPR framework should be grounded in Article 114 of the Treaty on the Functioning of the European Union, in keeping with its internal-market objective. The coalition has emphasised that EPR harmonisation at the EU level is essential to creating the conditions for a genuinely European market for secondary raw materials.
Producer-Led Responsibility and Governance
The coalition is also clear that EPR must remain producer-led. Producers should retain responsibility for decision-making within EPR systems, while public authorities take on a supervisory role. Importantly, the organisations have stressed that producer contributions must be reserved exclusively for waste-management activities and must not be treated as general public revenue.
The joint statement directly addressed the foundational principle behind EPR: “EPR stems from the polluter pays principle for a reason: producers should be responsible not only for financing waste management, but for organising the systems needed to collect, sort and recycle the products subject to EPR obligations that they place on the market.”
The groups are additionally seeking greater independence between EPR decision-makers and those organisations that receive EPR funding, as a key element of responsible governance.
Transparency and Accountability Requirements
To strengthen accountability, the coalition wants Producer Responsibility Organisations (PROs) to publish standardised annual information covering performance metrics, ownership structures, membership details, fee structures, eco-modulation criteria, budgets and the use of producer contributions.
The statement makes clear that transparency requirements should extend beyond PROs to include public authorities, municipalities and waste operators that receive EPR funding. This, the organisations said, would improve accountability and help assess whether contributions are proportionate and directed towards the intended outcomes.
Ring-Fencing Funds and the Net Cost Principle
The industry groups are calling for EPR funds to be ring-fenced for the specific product categories and waste streams for which they are collected. This, they argue, would prevent cross-subsidisation and ensure that funding is directed towards the infrastructure and operations required to meet recycling targets.
The statement also supports the consistent application of the net cost principle. Under this approach, revenue generated from the sale of secondary raw materials and other recovered outputs should be deducted from the costs covered by producers. Safeguards should also be put in place to prevent the same revenue or cost from being counted more than once.
The coalition has further specified that EPR funding should remain focused on collection, sorting, recycling infrastructure and related system improvements. Broader waste-prevention or reuse measures, they said, should not be funded through EPR where dedicated EU legislation already applies to those areas.
Reducing Complexity for Businesses
The proposed legislation should also work to reduce administrative complexity, particularly for small and medium-sized enterprises and for companies operating across multiple member states. On the matter of packaging EPR, the statement notes that member states should be permitted to require authorised representatives for producers based outside the EU that make products available on their markets. However, the coalition opposes any requirement for mandatory national representation for producers already established within the EU.
Strengthening Separate Collection
The coalition has called for stronger requirements on separate collection within the EPR harmonisation framework. This includes reporting on waste-stream coverage, population and territorial coverage, public-awareness measures and any applicable exemptions.
Communication campaigns, the groups said, should explain correct disposal and sorting practices, the role of separate collection and how active participation can contribute to higher-quality recycling outcomes. These measures, according to the statement, are necessary to lay the groundwork for a functioning European market for secondary raw materials.
The joint call reflects a shared view among these industry bodies that a strong and enforceable EU EPR framework, built on transparency, producer accountability and harmonised rules, is essential to advancing the circular economy and delivering on Europe’s recycling ambitions.
