Brussels, 27 May 2025 — Extended Producer Responsibility (EPR) stands as a cornerstone of the European Union’s sustainable waste management and circular economy policies. As the European Commission prepares to introduce the Circular Economy Act, it is essential to reinforce the role of EPR in meeting ambitious environmental and climate objectives.
Recognizing this critical juncture, EXPRA—the alliance of Producer Responsibility Organizations (PROs) across Europe—has published its key recommendations to guide EU policymakers in shaping a circular economy framework that is efficient, equitable, and sustainable.
The recommendations address several vital areas:
-
Safeguarding the Integrity of Extended Producer Responsibility: Ensuring that EPR systems remain robust, industry-led, and capable of adapting to evolving market conditions.
-
Transitioning EPR Systems to the Services of General Economic Interest (SGEI) Regime: Proposing a regulatory framework that balances public service obligations with flexibility and innovation.
-
Enhancing Transparency and Accountability in Online Sales: Addressing the growing impact of e-commerce by promoting clear reporting and responsibility mechanisms for online sellers.
-
Consumer and Citizen Engagement: Highlighting the importance of involving consumers and citizens actively in circular economy initiatives to drive behavioural change and awareness.
-
CO2 Performance Benchmarking for Waste Management Measures: Recommending the integration of carbon footprint metrics to evaluate and improve the environmental impact of waste management systems.
-
Ensuring Fair and Neutral Treatment of Producers and Manufacturers: Advocating for a level playing field where all economic operators, regardless of size or sector, are treated equitably.
-
Neutral Treatment of Commodities and Technologies: Supporting innovation by avoiding bias towards specific materials or technologies, allowing the best sustainable solutions to thrive.
These recommendations are designed to preserve and enhance EPR’s role as a powerful driver of the EU’s circular economy ambitions. By maintaining the industry-led nature of EPR, ensuring transparency particularly in the fast-growing online sales sector, and fostering meaningful public engagement, the EU can establish a regulatory environment that promotes sustainable growth and climate responsibility.
EXPRA stresses that the Circular Economy Act presents a unique opportunity for legislators to secure a future where EPR systems not only manage packaging and other waste streams efficiently but also stimulate innovation and collaboration across the value chain.
Joachim Quoden, Managing Director of EXPRA, commented: “The transition to a truly circular economy requires decisive and coordinated action. Our recommendations provide a roadmap to strengthen EPR frameworks, ensuring they remain fit for purpose in an evolving landscape. We look forward to working closely with EU institutions and stakeholders to implement policies that deliver tangible environmental and societal benefits.”
The full EXPRA Key Recommendations document is available for download here.