Extended Producer Responsibility Schemes have the potential to serve as an effective mechanism for financing the environmentally sound management of products at their end of their life cycle. Over the past decades, EPR schemes have contributed to significant improvements in waste collection and recycling rates across several sectors. Despite these advances, the implementation of EPR schemes across Member States continues to expose substantial structural challenges related to governance transparency, cost allocation and market functioning. Existing systems are often characterised by fragmented and insufficiently representative governance structures, inconsistent financing mechanisms, excessive administrative burdens, market distortions, insufficient transparency and weak enforcement. In many cases, Producer Responsibility Organisations (PROs) are primarily incentivised to minimise costs for producers rather than maximise environmental performance or circularity outcomes. This dynamic undermines investment certainty for recyclers and waste management operators while weakening incentives for eco-design and recycled material uptake.

The targeted revision of EPR schemes under the Circular Economy Act therefore represents an important opportunity to establish a clear, consistent, and competition-friendly framework that remains adaptable to national contexts. It is essential to redesign EPR systems so that they fully contribute to Europe’s circular economy, industrial competitiveness and strategic autonomy objectives. In this regard, effective EPR schemes can play a key role in supporting the objective of doubling the Circular Materials Use Rate (CMUR) to 24% by 2030, as outlined in the Clean Industrial Deal (CID).

To fully unlock the circularity potential of EPR schemes and establish them as a cornerstone of EU environmental policy and strategic autonomy objectives, Recycling Europe calls for a comprehensive reform of existing EPR frameworks and in particular, for the following measures:

1. Evidence-based and product-specific implementation of EPR schemes, applying EPR schemes only where market failures occur, where existing waste management systems fail to meet EU environmental targets (e.g., low recycling rates, negative-value waste streams).  

2. Ensuring transparency and full cost coverage of treatment costs, together with measures supporting a shift towards circularity.
3. Strengthening EPR governance and value-chain representation, ensuring that all actors of the value chain, including recyclers and reuse operators, are represented within the governing executive bodies of Producer Responsibility Organisations (PROs) to promote an industrial approach to resource circularity, foster best practices and mitigate conflicts of interests.
4. Simplification of administrative burden and digitalisation of audits and data collection. Duplicative or unnecessary audits conducted by PROs should be avoided, and reporting requirements should be streamlined through the use of a single shared platform for all PROs operating within the same sector.
5. Preserving competition through financial EPR Models instead of operational models. This will also help incentivise better services and higher performances, and avoid market distortion or excessive concentration of power.

6. Ensuring recyclers’ access to and control over waste at end-of-life, thereby supporting EU circularity and strategic autonomy objectives.
7. Eco-modulation of the EPR fees based on recycled content, recyclability, European preference, to fully leverage eco-design.
8. Strengthening enforcement and preventing free-riding by monitoring all actors involved in EPR schemes and by conditioning market access on the registration of producers in a dedicated registry.
9. Coherent harmonisation for efficient interaction between national and EU levels, clearly defining national and EU competences under the principle of subsidiarity and efficiency, to prevent free-riding, facilitate compliance, and account for national specificities.

This position paper therefore outlines Recycling Europe’s recommendations for the effective design of EPR systems in Europe by examining the structural shortcomings of existing schemes and proposing a coherent framework aimed at improving environmental performance while reinforcing the competitiveness and resilience of Europe’s recycling industry and advancing the EU’s environmental and strategic autonomy objectives.