Position papers

As technical trilogues concerning #PPWR progress, more than 20 organizations within the packaging value chain are urging EU legislators to remove references to ‘State-owned Producer Responsibility Organisations’ from the current negotiation text.

This proposed action could compromise the environmental objectives of the #PPWR revision by potentially reclassifying EPR fees as a form of taxation. In practical terms, this means there is a risk that fees collected from packaging producers could be allocated to fund the general state budget rather than being reinvested to promote packaging circularity.

Packaging producers remit EPR fees to cover the net costs associated with packaging waste collection, sorting, and recycling. With EPR schemes set to become mandatory for all packaging this year, ensuring the proper administration and reinvestment of EPR fees will be essential in increasing the amount of recycled packaging waste in Europe.

Please find below the joint industry statement from the following organizations:

AIM – European Brands Association
AISE International Association for Soaps, Detergents, and Maintenance Products
EXPRA – Extended Producer Responsibility Alliance
Natural Mineral Waters Europe (NMWE)
UNESDA – Soft Drinks Europe
Plastics Europe
Metal Packaging Europe (MPE)
The Alliance for Beverage Cartons and the Environment

Addressing the European Parliament’s proposal, a part of their amendments to the PPWR proposal, which advocates for the introduction of a mandatory target of 90% for the separate collection of all packaging materials, EXPRA, in collaboration with CITEO, ProsPA, ARA, DSD, SPV, Repak, worked collectively on a joint paper. This collaborative initiative was recently disseminated to key figures actively engaged in the Trilogue negotiations.

More than 100 associations, including EXPRA, representing Europe’s packaging industry, have written to EU Member States, urging them to uphold the Single Market or face huge supply chain disruptions when adopting their General Approach on the Packaging and Packaging Waste Regulation (PPWR). The joint statement warns that the current approach risks unraveling the Single Market by allowing Member States to introduce their own unique restrictions – a result that would seriously jeopardise supply chains and discourage investment in much-needed technologies.

Position Paper: State-run PROs” are another form of tax and cannot be considered as EPR since they contradict the General minimum requirements for EPR schemes (Art 8a of the WFD)


EXPRA believes that a state-run producer responsibility organizationis a contradictory mish- mash of conflicting terms that only leads to chaos. EXPRA calls upon Member States to reject such a dangerous notion as it has no place in a functioning free-market. Graver still, the proposed idea threatens the ability for the EU to move towards a Circular Economy despite the billions of euros being invested towards such a transition.

Position Paper: “Producer Responsibility Organizations should influence the EPR circle”

Highlighting the Significance of Producer Responsibility Organizations in Leading Member States

In Member States with a proven track record of excellence, such as Belgium and Luxembourg, Producer Responsibility Organizations have played a pivotal role in shaping the collection, sorting, and recycling landscape. These outstanding achievements ought to set the standard and offer valuable insights for all Member States seeking to elevate their performance.

In response to this, EXPRA is pleased to introduce a comprehensive position paper that delves into the details and provides solid justification for the substantial influence wielded by these organizations.