IN Brief:
- More than 40 industry organisations want an EU-wide framework for extended producer responsibility.
- Their six priorities include harmonised registration, producer governance, transparent reporting, and ring-fenced recycling funds.
- The intervention comes after PPWR implementation began while EPR administration remains largely fragmented between national systems.
EUROPEN and more than 40 industry organisations are calling for the forthcoming Circular Economy Act to establish a more harmonised EU framework for extended producer responsibility, arguing that fragmented national systems are limiting investment in recycling and obstructing the movement of secondary raw materials across the single market. Their joint statement sets out six priorities covering a directly applicable EU framework, producer led governance, common reporting, ring-fenced funding, simpler registration, and stronger separate collection.
The proposed framework would be based on Article 114 of the Treaty on the Functioning of the European Union, which the signatories see as a route to reducing differences between national EPR systems without removing producer responsibility itself. Companies placing similar packaging on several European markets can currently face different registration procedures, reporting formats, fee structures, and governance arrangements, even when the physical pack and material specification remain unchanged.
Producer governance sits alongside harmonisation because the coalition wants businesses that fund EPR systems to retain a direct role in how those systems are managed. The same statement calls for producer fees to be ring-fenced for the waste streams that generated them, linking the money collected from packaging more visibly with the collection, sorting, and recycling infrastructure needed to return material to productive use.
Comparable reporting would support that link by giving producers, regulators, and waste operators a more consistent view of material flows and system performance across member states. The organisations are also seeking simpler registration for companies operating in several countries, a change aimed particularly at reducing duplicated administration where the same information is submitted repeatedly through different national portals.
Separate collection forms the physical counterpart to those administrative changes because secondary material markets cannot expand solely through common forms and fee rules. Recyclers need sufficient quantities of reasonably clean material, and producers seeking recycled content need confidence that collection and sorting systems can deliver feedstock of predictable quality, leaving consumer participation and municipal infrastructure as part of the same industrial equation.
The Packaging and Packaging Waste Regulation began applying generally across the EU on 12 August 2026, bringing more harmonised requirements for packaging composition, recyclability, conformity documentation, and waste reduction only weeks before the coalition published its EPR proposals. Product rules are becoming more consistent at European level while the financing and administration of end-of-life systems remain substantially national, creating a split that is especially visible to companies selling packaged food and drink across several markets.
Packaging records now have to support more than a converter’s technical specification, since material composition, pack weight, food contact status, recyclability, market destination, supplier declarations, and conformity evidence can all affect legal or financial obligations. A change in resin, coating, laminate, or pack weight may originate several tiers upstream, but the producer placing the finished product on the market still needs enough controlled data to determine how that packaging should be reported and what obligations attach to it.
The administrative burden becomes more pronounced when EPR and PPWR data overlap without using the same national systems, because a single packaging change can trigger updates to product documentation, supplier records, registration data, and fee calculations in several jurisdictions. Multinational food and beverage businesses can absorb part of that complexity through central compliance teams and packaging databases, whereas smaller producers face the same legal variation with fewer specialist resources.
Ring-fenced EPR funding would not guarantee additional recycling capacity, but it would make the connection between producer payments and infrastructure investment more explicit, which is central to the coalition’s argument. Recycled content targets and circularity claims depend on actual secondary material being available at the required quality, so a system that collects fees without expanding effective collection and recycling capacity leaves producers paying into a mechanism that may still struggle to supply the materials regulation increasingly encourages them to use.
The European Commission is still developing the Circular Economy Act, which means the six industry priorities remain lobbying positions rather than agreed policy. Their significance lies in the timing: PPWR has already moved packaging design and documentation further towards EU-wide rules, while EPR administration remains fragmented enough for more than 40 organisations to seek another layer of harmonisation through the next legislative package.
Any Commission proposal will still have to pass through the EU legislative process, where the scope, legal basis, governance model, and treatment of national schemes could change. Until then, producers remain responsible for navigating the existing patchwork, while the coalition is seeking fewer parallel registration systems, more comparable data, and a closer link between producer fees and the infrastructure needed to keep packaging materials in circulation.
