Dear Esteemed Readers,
We hope this EXPRA Newsletter finds you well and energised as we move through the third quarter of 2025 and enter the final stretch of the year.
The past months have been particularly important for EXPRA. Our Board convened in Brussels for its autumn meeting, preceded by the traditional informal dinner with members and guests. Hosted at the Fost Plus / EXPRA office, the meeting focused on the most recent legislative developments affecting producer responsibility organisations. Key discussions addressed sub-legislation under the Packaging and Packaging Waste Regulation (PPWR), EXPRA’s ongoing contributions to the forthcoming Circular Economy Act, and our input to the Environmental Omnibus Consultation.
We have been very active on the legislative front and published several press releases this quarter, including:
• State-Run PROs in Waste Framework Directive: A Dangerous Step Back (Brussels, 21 September 2025) — EXPRA expresses deep concern following the European Parliament’s 9 September vote on the revised Waste Framework Directive and flags risks linked to proposals that could enable state-run PROs without a clear producers’ mandate.
• Online Marketplaces: Unlocking Their Role in Extended Producer Responsibility (17 September 2025) — EXPRA joined 63 NGOs, industry associations and consumer groups urging policymakers to recognise online marketplaces as economic operators under EU law and to ensure seller traceability, proof of EPR registration and financial accountability for unpaid fees.
• EXPRA Responds to the Environmental Omnibus Consultation — EXPRA welcomes the opportunity to streamline EU regulation while protecting environmental ambition, and recommends two targeted fixes to safeguard EPR functioning: alignment of the new producer definition with the calendar year from 1 January 2027, and an EU-wide, proportionate Authorized Representative regime.
• EXPRA & EPRO Joint Feedback on the Single-Use Plastics Directive Implementing Act — joint comments on the draft rules for calculating, verifying and reporting recycled content in single-use plastic beverage bottles.
Among all developments this quarter, the most significant moment for EXPRA was the CJEU judgment in case C-254/23 (Interzero) on 10 July 2025. The Court confirmed that a Member State may lawfully designate a single not-for-profit organisation to fulfil EPR obligations as a Service of General Economic Interest (SGEI), provided certain conditions are met — notably a clear public interest objective, well-defined legal obligations and transparency and governance safeguards. The ruling brings important legal clarity for Member States designing or reforming EPR systems and affirms that collective, non-profit models can be compatible with EU law when proper checks and balances are in place.
We hope you find this edition both informative and engaging: inside you will find member updates, policy perspectives, and a calendar of EXPRA’s upcoming events.
As always, EXPRA remains committed to closely monitoring these developments and providing strategic input to ensure that EPR frameworks continue to deliver environmental and economic benefits across the world.
Warmest regards,
Your EXPRA Team
Joachim, Monika & Valeria