Producer responsibility

Packaging, electronic devices, tires, batteries, textiles: there are many products that we as consumers encounter in our daily lives that are subject to “Extended Producer Responsibility” (EPR). And this will only become more product groups in the (near) future, such as shoes and diapers. Still, there is much to criticize about the system. While it often allows for better collection and covering its costs, what about the sustainability of the products? And who is actually in charge?

what exactly are we talking about?

There is now “extended producer responsibility” for a host of products. Think tires, packaging, electronic devices, and recently in the Netherlands also textiles. It is seen as an effective way to make producers responsible for the products (and associated waste) they produce. The idea is a good one: we make polluters pay for the environmental impact of their products and that will motivate them to change their business model and be more environmentally friendly. But in practice, the results have been disappointing.


No optimal EPR without system change

One thing is clear: EPR is here to stay. Yet we have noted before (as here and here) that much goes wrong within EPR systems, much of which can be traced back to poor governance. The role of government is too limited, many stakeholders feel sidelined, and enforcement is poor. Because of the way EPR legislation is designed and its often poor implementation, EPR’s potential is severely underutilized and producers are not held sufficiently accountable for the environmental damage they cause. Fair Resource Foundation wants to address that.

Europe believes in EPR

Comprehensive producer responsibility is established at the European level in several dossiers. First, the Packaging and Packaging Waste Regulation (PPWR): among other things, it talks about the investments that producer organizations (PROs) should or should not make in reuse systems, for example. It also looks at mandatory eco-modulation (tariff differentiation based on sustainability criteria) for packaging. However, the main provisions for EPR are set out in the Waste Framework Directive (WFD). This “Waste Framework Directive” defines, among other things, the waste hierarchy and ground rules for EPR systems and associated PROs. An influential dossier thus.

Netherlands to review EPR

The message that EPR is not functioning optimally has also reached the Dutch government. After Secretary of State Heijnen presented her vision for EPR to the House of Representatives in April 2022, there were various motions submitted and adopted. As a result, the Ministry of I&W decided to initiate a process to achieve improvement proposals. These were published in October this year. In collaboration with Minderoo, Fair Resource Foundation also conducted an analysis of the operation of EPR systems. The results are included in a position paper published in October 2023.

Latest articles on Producer Responsibility


Study: tackling litter mainly helps producers of single-use products

Full report (EN) Each region of Belgium has a different litter policy. Flanders has a -20% target for 2022 compared to 2015, which has not been achieved. In Wallonia and Brussels, agreements on litter are less clearly formulated and there is a lack of proper monitoring. In no region is litter tackled at the source. Each region of Belgium has a different litter policy. Flanders has a -20% target for 2022 compared to 2015,

Read more

Out of sight, out of the system: producers evade EPR-costs by exporting waste to Africa

Extended Producer Responsibility (EPR) schemes are flawed for various reasons. We already wrote about the governance issues surrounding EPR and the way in which it does not sufficiently address product design in e.g. the textile sector. A new report by Circular Economy Lab (CEL) and the European Environmental Bureau (EEB) places the focus on another flaw: discarded electronic devices and vehicles are often given ‘another life’ outside of Europe, mostly

Read more

who works on this

Janine Röling

EPR and EU policy coordinator