As part of European circular economy policy, a reform of Extended Producer Responsibility (EPR) systems is currently under consideration. For producers and businesses in the EU, potential changes could have significant implications for cost structures, obligations and the organisation of existing take-back and recycling systems.
In this context, Zero Waste Europe criticises the fact that existing systems have so far focused primarily on waste management rather than on waste prevention, reuse and repair. According to the organisation, this is also reflected in the current circular economy figures: The circular material utilisation rate in the EU stood at 12.2 per cent in 2024, whilst the policy target for 2030 is 22.4 per cent. At the same time, waste volumes continue to rise in certain sectors, such as packaging. Against this backdrop, ZWE is calling for a fundamental overhaul of producer responsibility schemes.
Split EPR Fees: Proposal for the allocation of producer fees
The proposal envisages splitting the existing EPR fees into two separate budgets. A portion would still be set aside for conventional activities like gathering, sorting, and recycling. The second part introduces an extra fee for waste prevention, which helps fund programmes that extend product lifespans, like repair services, reuse programmes, or refurbishment initiatives. Medium-scale R strategies in particular – reuse, repair and refurbishment – would benefit from this.
For retailers and producers, however, this model would mean that they would have to assume greater financial responsibility and additionally fund all manner of programmes for waste prevention, reuse and repair. Besides increased expenses, companies would also face additional pressure from structural changes to the financing system.
‘Transition to Circularity’ fund as a transitional model
According to ZWE, there is insufficient cost data available for reuse and repair systems in many EU Member States. It is therefore proposed that a mandatory, time-limited ‘Transition to Circularity’ fund be established by 2030, whereby a minimum proportion of the budgets of organisations for producer responsibility (PROs) is specifically allocated to waste prevention and reuse measures. The fund is intended to serve as a transitional mechanism until specific, data-driven fee models for waste prevention measures can be developed. In ZWE’s view, repair and reuse initiatives are currently often financed from public funds. The organisation argues that, in line with the polluter-pays principle, producers should contribute more to the financing of such measures and also calls for greater oversight of EPR schemes with clearer control mechanisms and binding targets for PROs.
EU Circular Economy Act 2026: How the proposed changes could impact producers
The planned Circular Economy Act is expected for mid-2026. It aims to modernise EPR schemes, create an internal market for secondary raw materials and align EU policy with the circular economy. Should the shared EPR fees be used as a central reform instrument, as envisaged by the ZWE, retailers and producers should brace themselves for even greater financial responsibility.
In contrast, VERE advocates the consistent application of existing EU regulations such as the Critical Raw Materials Act and more efficient controls on imported goods. Party due to the high costs and the emerging data protection and liability issues, a central EU-wide reporting platform for Extended Producer Responsibility is viewed critically. Instead, digitalisation and harmonisation on an EU-wide level should take place gradually through common data standards, standardised interfaces and open-source solutions. VERE also suggests practical product and packaging labels. Unified labelling or digital product passports with clear minimum data could address this issue. Public institutions should strengthen sustainability criteria and binding recycling quotas, rather than additionally overloading retailers and producers.
VERE e.V. is in contact with the relevant stakeholders and keeps its members informed of further developments via the “VERE Insider”. Profit from our dedication and become a VERE member right away!
