EXPRA has published its recommendations on how digitalisation can facilitate Extended Producer Responsibility compliance in the framework of the future Circular Economy Act.
As Producer Responsibility Organisations operating at the forefront of circular economy implementation, EXPRA fully shares the European Commission’s ambition to make EPR compliance simpler and more accessible for producers. Digital tools can play an important role in reducing duplication, improving access to information and supporting companies that report across several Member States.
However, EXPRA underlines that simplification should not be understood as centralisation for its own sake. EPR systems are deeply rooted in national legal, operational and financial frameworks. Registration, reporting, fee calculation, auditing and enforcement are not all the same process, and they should not necessarily be treated through a single uniform digital solution.
EXPRA therefore calls for a pragmatic approach based on three pillars, the development common dataset for products and packaging, better access to reliable information on EPR and explore the development of an EU EPR Gateway, not-for-profit, to enhance EPR registration
A key recommendation is the development of a common European product and packaging dataset, which could support the rollout of a digital Product and Packaging Passport. Such a tool would assist producers with their reporting by ensuring consistency in reporting and data sharing across national and regulatory boundaries. This would reduce duplication without imposing a one-size-fits-all declaration model”
EXPRA also recommends the creation of a centralised EU EPR database, publicly accessible and regularly updated, providing a clear map of existing EPR schemes, PROs, National Registers, contact details, reporting procedures and authorised representatives. Such a database would be a practical first step towards simplification, helping producers understand where and how they need to comply.
On registration, EXPRA supports exploring an EU EPR Gateway, provided that it remains a not-for-profit digital tool, supervised by a public authority such as the European Commission, and interlinked with National Registers. The purpose of such a gateway should be to facilitate registration and improve transparency, not to replace national EPR systems or interfere with national financial flows.
At the same time, EXPRA stresses that core EPR enforcement measures must remain at national level.Reporting to national PROs, the processing of EPR fee payments, audits and data accuracy controls are essential to safeguard the financial stability and accountability of EPR systems. A producer cannot become compliant simply by registering on a central EU platform; direct contractual relationships with designated PROs remain necessary to ensure clear legal liability and enable auditing.
EXPRA also calls for a clearer EU framework for authorised representatives, including harmonised conditions for appointment, liability rules, transparency obligations and public information on the companies represented by each authorised representative.
Finally, EXPRA highlights that the costs of any EU EPR Gateway or digital tool must remain transparent and proportionate to the benefits generated. If financed by PROs, such costs would ultimately be reflected in EPR tariffs and could create an additional financial burden for producers, including SMEs.
Digitalisation can and should make EPR compliance easier. But to be effective, it must strengthen existing systems, not undermine them.
For EXPRA, the way forward is clear: develop a common packaging and product dataset, improve access to information, support interoperability and preserve the national accountability mechanisms that allow EPR systems to deliver real circular economy results.