The design of Extended Producer Responsibility (EPR) systems has a decisive influence on whether European Union Member States can meet the requirements of the new EU Packaging and Packaging Waste Regulation (PPWR). This is the conclusion of a study commissioned by Europen and carried out by Circpack, a consultancy and certification firm that is part of the Veolia Group. The analysis shows that specific design features – such as differentiated fee models, efficient organisation, high-quality data and transparent financial flows – are key determinants of success in packaging recycling.
Differences across Europe in packaging recycling and EPR systems
For the study, Circpack analysed the EPR systems of all 27 EU Member States using Eurostat data from 2023, national registers, financial and operational reports from Producer Responsibility Organisations (PROs), and its own dataset covering 13 packaging sub-categories. Belgium, Italy, Spain, Germany and Hungary were examined in greater depth. Circpack notes that Veolia operates collection, sorting and recycling facilities in several countries and that some of the datasets are based on the company's own operational data.
The study reveals significant differences in packaging recycling performance across Europe. In 2023, just under 80 million tonnes of packaging waste were generated across the 27 EU Member States. The average recycling rate was 64.1 per cent, ranging from 79.7 per cent in Belgium to 37.3 per cent in Romania. Only 42.1 per cent of plastic packaging was recycled on average overall.
The study identifies differentiated EPR fees, which take into account material type, packaging format and recyclability, as a key success factor. Equally important is the targeted use of revenue to finance collection, sorting and recycling infrastructure. Countries with differentiated fee models achieve recycling rates that are, on average, 16.5 percentage points higher. For rigid plastic packaging (i.e., particularly robust, dimensionally stable packaging used for transport, storage or product presentation), recycling rates reach 52 per cent compared with just 31 per cent in countries without such models. Higher fees alone do not necessarily lead to better results; rather, it is the way the fees are structured and allocated that ultimately determines the success of an EPR system.
Governance and data quality are vital to recycling success
Circpack identifies the greatest shortcomings in recycling infrastructure and in the demand for recycled materials. Flexible plastic packaging, in particular, remains a challenge due to insufficient sorting and processing capacity. Governance and data quality are also critical. Whilst countries with a single Producer Responsibility Organisation (PRO) achieve higher recycling rates on average, the study concludes that clear governance, transparent financial flows and a robust data foundation are the decisive factors. Countries with high-quality data achieve an average recycling rate of 69.6 per cent, whereas those with lower levels of transparency reach only 56.2 per cent. Belgium is highlighted as a model for effectively linking financing, performance standards and packaging data.
In a country-by-country comparison, Belgium leads with a packaging recycling rate of 79.7 per cent, followed by Italy (75.6 per cent), Spain (70.5 per cent) and Germany (69.4 per cent). Although Germany benefits from the LUCID packaging register, its performance is held back by competing systems and the absence of standardised EPR fees. Hungary ranks last among the countries analysed, with a recycling rate of 42.8 per cent. Circpack sees the PPWR as an important step forward but calls for more differentiated fee structures, more efficient governance, improved data quality and greater transparency in financial flows. The planned Circular Economy Act could further harmonise EPR systems across Europe, a development that VERE expressly welcomes.
In general, VERE appreciates the study's approach, which advocates transparent and objective fee structures that ensure and reflect the efficient management of recycling obligations in line with the principles of Extended Producer Responsibility. This contrasts with high, non-transparent and flat-rate fees, which may place an unnecessary financial burden on obligated retailers and producers while generating unjustified costs.
VERE e.V. remains in close contact with the relevant stakeholders and will continue to keep its members informed of further developments via the “VERE Insider”.
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