EURATEX and EuroCommerce push harmonised EU EPR rules in CEA

European industry groups including EURATEX and EuroCommerce have issued a joint statement calling for a "strong, harmonised and enforceable" EU framework for Extended Producer Responsibility (EPR) in the upcoming Circular Economy Act (CEA). Their central demand: replace divergent national waste rules with a directly applicable EU regulation for EPR schemes and their waste streams.

EPR already operates across the EU to finance waste collection, sorting and recycling. But the statement, reported by the signatory organisations, says performance remains uneven between member states and that divergent national rules limit how well existing systems work. The groups want the legislation to move Europe away from "fragmented" waste management and towards a "functioning internal market" for secondary raw materials.

What legal basis do the groups propose?

The coalition wants the framework built on Article 114 of the Treaty on the Functioning of the European Union, which anchors the proposal in the EU's internal-market objective rather than environmental law alone. Common rules, the statement argues, would cut regulatory differences, support cross-border value chains and give companies running circular business models more certainty. Sector-specific requirements could sit alongside the general regulation where necessary.

Who controls the money and the decisions?

The groups insist EPR must remain "producer-led", with producers keeping decision-making responsibility while public authorities supervise. Producer contributions, they say, should fund waste-management activities rather than flow into general public revenue.

"EPR stems from the polluter pays principle for a reason: producers should be responsible not only for financing waste management, but for organising the systems needed to collect, sort and recycle the products subject to EPR obligations that they place on the market," the statement read.

What transparency changes are on the table?

The coalition wants greater independence between EPR decision-makers and the organisations that receive EPR funding. Its specific asks include:

• Producer Responsibility Organisations (PROs) must publish standardised annual information on performance, ownership, membership, fee structures, eco-modulation criteria, budgets and the use of producer contributions.
• Transparency rules should extend to public authorities, municipalities and waste operators receiving EPR money.
• EPR funds should be ring-fenced for the product categories and waste streams they were collected for, to prevent cross-subsidisation.

The groups say these measures would improve accountability and show whether contributions are proportionate and directed to intended outcomes.

How should costs be calculated?

The statement backs consistent application of the "net cost principle". Revenue from selling secondary raw materials and other recovered outputs should be deducted from the costs producers cover, with safeguards against counting the same revenue or cost twice. EPR funding should stay focused on collection, sorting, recycling infrastructure and related system improvements. Broader waste-prevention or reuse measures should not draw on EPR money where dedicated EU legislation already applies.

What does this mean for small firms and importers?

The proposed legislation should reduce administrative complexity for small and medium-sized businesses and for companies operating in several member states. For packaging EPR, member states should be able to require authorised representatives for producers based outside the EU that sell into their markets. The coalition opposes mandatory national representation for producers already established inside the EU.

On collection, the groups want stronger "separate collection" requirements, including reporting on waste-stream coverage, population and territorial coverage, public-awareness measures and exemptions. Communication campaigns, they argue, should explain correct sorting and disposal and how participation supports higher-quality recycling. Together, they say, these measures would create the conditions for a genuine European market for secondary raw materials.

For sourcing and compliance teams, the statement sets out the position to track as the CEA takes shape: a single EU-level EPR regulation could replace today's patchwork of national fee systems and reporting formats, and brands selling across Europe should map their PRO obligations now against the transparency and ring-fencing demands likely to shape the final text.