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Extended Producer Responsibility (EPR)

Europe creates mountains of waste every single day. Packaging, electronics, textiles; everything we use eventually needs to be collected, recycled, or safely disposed of.

For years, the costs of handling that waste were pushed onto local councils and, ultimately, all consumers. In fact, everybody paid equally and not for what they produced and used. In that way it was not fair, it was not transparent, and it did not encourage companies to design products that last longer or can be recycled. And that is why the EU implemented EPR.

Lower taxes (and so lower prices) for more sustainable alternatives will lead to less waste, smarter design, and a real step forward towards a circular economy.

EPR guides, other laws govern

EPR is not a law. Instead, it is a principle that guides many (new) laws linked to improving reuse, repair and recycle solutions. For example, EPR first appeared in regulation for electronics (WEEE Directive) and batteries. Today, it is being expanded to cover more product groups (such as textiles) and strengthened with tougher requirements, like the new Packaging and Packaging Waste Regulation (PPWR).

To be clear: EPR is the principle, not the law itself. The PPWR is (for example) a separate EU law, but it is based on the EPR principle.

Making sense of EPR

The goal of Extended Producer Responsibility is simple: producers should take responsibility for the entire lifecycle of the products they put on the market. But while the idea is straightforward, the way it works in practice is a little more complex. EPR is not a one-size-fits-all system. It’s carefully designed to deal with the fact that different products and materials create very different waste challenges.

A plastic bottle, for example, has a completely different recycling journey than a washing machine. That’s why each product group has its own rules, fees, and reporting requirements. One thing all schemes have in common is that fees are often calculated per kilogram of material placed on the market.

But it doesn’t stop there — the type of material also matters. The harder something is to reuse, repair, or recycle, the higher the cost. On the other hand, more sustainable material choices are rewarded with lower fees (also called ecomodulation). Think about textiles: cotton certified under Oeko-Tex or Better Cotton (BCI) can have lower EPR costs compared to standard cotton, because it’s produced in a more responsible way.

The same applies to plastics; recycled plastic usually comes with lower fees than virgin plastic, because it reduces waste and supports the circular economy. In this way, EPR does more than just shift costs from taxpayers to producers.

It actively pushes companies to make better design and material choices, rewarding those who invest in sustainability and nudging the market towards smarter and more (real measured and proven) sustainable solutions.

How it is managed
A Producer Responsibility Organisation (PRO) is a third party organisation that helps companies meet their EPR obligations. These organisations (each country has their own PRO’s) are funded by the EPR fees paid by their member companies. In return, PROs manage the collection, sorting, and recycling of products at the end of their life, offering an efficient way for companies to comply with EPR rules across different countries.

Common categories explained

As said, EPR is not a law but it guides laws in different categories. Below some of the laws and directives explained including its implications.

  1. Packaging (PPWR): Packaging is one of the most widespread EPR categories. Producers pay fees based on the type, weight, and material of the packaging they place on the market.
  2. Textiles: (Waste Framework Directive): given the rising focus on textile waste in recent years, specific EPR related schemes are now being developed for this category and need to be implemented between 2025 and 2027. Some countries like France and the Netherlands already started some years ago.
  3. Electronics: (WEEE- waste electrical and electronic equipment): focuses on safely managing hazardous materials in electronics and ensuring valuable components are recovered. Already fully active, but targets for collection and treatment continue to get stricter.
  4. Batteries: (Batteries Directive): due to hazardous contents and valuable materials, the schemes for batteries ensure their proper collection and recycling to prevent pollution and recover critical raw materials. Although already active since 2007, new EU-wide rules must be in place by August 2025. These include new reporting and recycling targets.

The varying obligations

EPR obligations are made on different levels and are different per law or directive and also often different per country. The obligations explained that can apply depending on the law are:

  1. Financial contributions: Producers pay fees based on the weight or number of products they place on the market. The level of the fee depends on the material: recycled or certified sustainable materials are charged less, while harder-to-recycle materials are charged more. This is the main money stream; the funds collected are then used to finance collection, recycling, awareness campaigns, etc.
  2. Collection targets: Producers (often through their industry organisations) must ensure that a certain percentage of the products they put on the market are collected at end-of-life. Example: In the Netherlands, the “statiegeld” (deposit return) organisation, funded by the beverage industry, was fined when bottle collection targets were not met. So yes, the branch pays, and the PRO manages the obligation. 3. Recycling and recovery targets It’s not enough just to collect waste. A certain percentage must actually be recycled into new materials, or in some cases recovered for energy. Collection = how much is taken back. Recycling/recovery = what actually happens with that collected material.
  3. Design requirements: Producers are encouraged (and in some cases required) to design products that are easier to recycle, reuse, or repair. These link back to the fees: if your product is designed sustainably, you often pay a lower fee per kilo (please read our ESPR article to learn more).
  4. Reporting: Producers must report what they place on the market and how waste management obligations are being met. This reporting covers all the points above: how much was put on the market (financial contributions), how much was collected (collection targets), how much was recycled/recovered (recycling targets), and how your product design meets requirements.

What does this mean for you

What that means in practice

As every country has its own PRO’s, you need to register with the local compliance organisation for each product group (packaging, textiles, electronics, batteries, etc.) and check if you need to report based on your company size.

Report the volumes you put on the market (normally in kilos or units, using supplier data or official reference tables).

Pay the fees based on material and weight. More sustainable or recycled materials usually cost less.

There is no European database that has a complete overview of all PRO’s in all member states. Please check your country specific website or (for urgent questions) ask Solo midocean.

What does Solo midocean do?
We will deliver the relevant documentation for each of your requirements and are working on tools to make it easy to make your calculations.

Insight library: Legislations made easy