Extended Producer Responsibility (EPR)
What is Extended Producer Responsibility (EPR)?
Extended Producer Responsibility (EPR) is a policy approach that makes producers financially and organisationally responsible for the end-of-life management of the packaging they place on the market. Under PPWR and related national schemes, producers must register with an authorised EPR scheme, report packaging volumes, and pay fees that fund collection, sorting, and recycling of packaging waste.
Why It Matters
Any business placing packaged goods on an EU or UK market is likely to fall within scope of an EPR scheme in that country, even if the packaging itself was designed and manufactured elsewhere. Registration and reporting obligations sit with the producer placing the goods on that specific national market, not just the manufacturer.
Because EPR schemes are administered nationally rather than centrally, businesses selling across multiple EU member states may need to register with several different schemes, each with its own reporting format, fee structure, and deadlines.
Failure to register or report accurately can result in fines, back-payment of fees, and in some cases restrictions on continuing to place packaging on that market.
Key Requirements
Who Is Required to Comply with EPR?
PFAS-related obligations are relevant to any business placing packaging or packaged products on the EU or UK EPR obligations generally apply to:
- Producers and brand owners placing packaged goods on a given national market
- Importers bringing packaged goods into a country from abroad
- Online marketplaces and fulfilment providers in some jurisdictions, where the underlying seller is not established locally
This applies across most packaging types, including:
Retail and consumer packaging
E-commerce shipping packaging
Transport and grouped packaging
Responsibilities Relating to EPR
Businesses in scope of EPR are generally expected to:
- Identify and register with the correct scheme in each relevant national market
- Report packaging volumes and material types on the required schedule
- Pay applicable EPR fees, which are often weighted by recyclability and material type to incentivise eco-design
- Retain records supporting reported volumes in case of audit
- Monitor scheme changes as PPWR harmonisation progresses across member states
EPR and Technical Documentation
Businesses should retain packaging volume records, material declarations, and registration confirmations for each scheme they participate in, since these form the audit trail regulators and scheme administrators may request.
Packaging Compliance Under PPWR
Selling packaged products in the EU? Every unit now falls under the Packaging and Packaging Waste Regulation (EU) 2025/40. Euverify handles your Declaration of Conformity, technical file, and compliance documentation as part of your plan, no expertise required on your end.
Related Terms
Further Reading
