The term Extended Producer Responsibility, or EPR, sounds almost self-explanatory and promising. A producer places a product on the market. That product eventually becomes waste. Instead of the producer’s responsibility ending at the point of sale, responsibility is extended into the post-consumer stage. This is how EPR is described in policy literature.
The OECD defines it as an approach under which producers become responsible for their products throughout the life-cycle, including after use. The intention is not only to finance collection and treatment, but also to encourage waste prevention, better product design and improved recycling.
On paper, this sounds like an important answer to one of the central problems of modern consumption: companies should not be able to place increasingly complex products and packaging on the market while leaving municipalities and society to deal with the waste.
Yet, does it achieve in practice what it promises on paper?
In our last insight we had a look at how the EPR system for packaging waste in three major European economies function in practice; i.e.g Luxembourg, France, and Germany. In all three countries, producers fulfill much of their responsibility towards packaging waste through collective organizations. The producers generally do not collect their own packaging after consumers discard it. Nor do they usually operate recycling facilities themselves.
Instead, a company places packaging on the market, declares the amount and type of packaging, and pays a fee to a Producer Responsibility Organization or equivalent scheme. That organization then finances or organizes some combination of collection, and sorting.
The physical waste, meanwhile, continues to move through municipal collection systems, and after sorting it may have an eventual destiny with either of private waste contractors, recyclers, waste traders and even waste exporters to destinations outside the EU. This is still EPR in the formal sense. The producer has acquired a financial obligation that did not previously sit directly with it.
Therefore, in summary, the EPR cycle can look like this: packaging waste → EPR fee → slightly higher product price → consumer pays → waste is collected and is out of sight. In Luxembourg, France and Germany, this basic model has operated for years. Before the updated Packaging and Packaging Waste Regulation (EU) 2025/40 became applicable in August 2026, there were already recycling and prevention targets, but the producer’s practical obligation was still largely centred on financing or organizing collection and treatment rather than directly redesigning or eliminating packaging.
In addition, there has also been no general obligation to recycle the waste in the same country where it was generated. Once collected and sorted, packaging waste can be sent elsewhere for recycling or other treatment, subject to waste-shipment rules.
The arrangement may look considerably more like a dedicated financing mechanism for waste management than direct producer responsibility for the end-of-life of a product as the concept commits itself to theoretically.
The OECD itself has noted that fee structures used by Producer Responsibility Organizations are often relatively simple, frequently based mainly on material and weight, and consequently provide only weak incentives for producers to change product design. This is why governments have increasingly introduced so-called eco-modulated fees, where less recyclable products are supposed to pay more.
The organization between the producer and the waste
The Producer Responsibility Organization or PRO has its own operational and financial requirements. It must collect contributions, contract services, meet regulatory targets and maintain an economically viable waste-management system.
Once the producer has declared the packaging and paid the required contribution, its direct involvement with that specific package may effectively end. That creates a separation between the company that designed the package and the organizations actually handling the waste.
The waste then enters an independent chain:
household → collector → sorting facility → trader or recycler → secondary material market, other treatment such as incineration or landfill.
Whether the package is actually recycled depends on far more than the producer’s payment. It depends on collection quality, contamination, sorting technology, market demand for recycled material, treatment capacity and the economics of recycling. If recycling does not make economic sense, additional regulation may be necessary to require it.
That is an important distinction: EPR financing does not automatically create a circular material loop.
Trade of Waste
For years, European plastic waste has been traded internationally after collection and sorting. An EPR contribution paid in the country where the packaging was sold does not necessarily mean that the resulting material will also be recycled there.
In 2024, around 1.5 million tonnes of sorted European plastic waste were exported for recycling abroad—equivalent to about 12% of the plastic sorted for recycling. Importantly, Plastics Europe notes that the final recycling yield of this exported material cannot currently be traced reliably.
The EU has now tightened these rules significantly. Since May 2026, exports of plastic waste to third countries require prior informed consent, and from 21 November 2026 plastic-waste exports to non-OECD countries will be prohibited for at least 2.5 years. Exporters will also face stronger obligations to demonstrate that receiving facilities manage waste appropriately.
Europe has not completely closed the plastics loop
Europe has made substantial progress in sorting, collection and recycling infrastructure, yet plastic packaging is far from operating as a fully circular material system. EPR is only one policy instrument among many and on its own is not written to guarantee circularity of plastic; at least not in the three countries discussed here.
When packaging becomes more recyclable because legislation explicitly requires recyclability, or when recycled content rises because legislation mandates minimum percentages, those results should not automatically be attributed to EPR.
Europe’s official recycling figures can give an incomplete picture of circularity. In 2024, only 29.6% of collected post-consumer plastic waste in Europe was recycled, while more than 70% was incinerated or landfilled. Even when plastic enters a recycling facility, material losses are significant: the European Environment Agency estimates that only around 65% of plastic waste entering mechanical recycling plants emerges as recyclate.
This matters especially for countries now designing their own systems.
Simply adopting the terminology of Extended Producer Responsibility does not guarantee less virgin material, more reusable packaging, higher-quality recycling or lower plastic leakage.
Those outcomes depend on the actual architecture of the system.
Financing waste management is not necessarily the same as producer responsibility
EPR can and has provided important benefits in these three European countries. It generates predictable financing for collection, improves information on the quantities of products entering the market, establishes measurable targets and reduces the share of waste-management expenditure that must come directly from general public budgets. However, it does not necessarily reduce the cost of waste management for the consumers, nor does it result in less waste to begin with.
If producers mainly comply by paying a collective fee, if that cost can largely be passed into consumer prices, if waste management continues through essentially the same municipal and commercial infrastructure, and if the producer has little direct connection to whether its own packaging is ultimately recycled, then EPR may function primarily as a financing mechanism.
That is not necessarily useless. It is simply different from what the terminology suggests. The key question for countries now developing EPR systems should therefore not be:
Do we have an EPR law?
It should be:
What behavior will our EPR system actually change?
Have you read our previous insight?
Who Really Pays for Household Waste? A Look at Luxembourg, France and Germany