The inconsistent application of Extended Producer Responsibility among Member States constitutes an obstacle to the functioning of the European internal market. The Circular Economy Act aims to identify potential unnecessary burdens associated with Extended Producer Responsibility and to promote simplifications, particularly for the benefit of small and medium-sized enterprises (SMEs). For this reason, this section of the SME panel on the EU Commission’s Circular Economy Act was of particular importance to many SMEs, especially VERE members. When asked which support measures would make it easier for companies to comply with Extended Producer Responsibility regulations, VERE took the following position:
The panel survey strongly highlights the potential benefits of an “EU One-Stop Shop". This describes an online platform provided by the EU that enables users to manage all tasks related to EPR requirements. Although the concept is appealing, implementing it across the EU’s 27 member states and at least 81 waste streams is unlikely to be practical. In the context of global competition, enhancing competitiveness – particularly through reducing bureaucracy – should be prioritised. To achieve this, prompt and effective measures must be taken to remove administrative barriers and impediments. Focusing solely on the "big picture" does not provide sufficient short-term solutions when immediate results are required. Acting as an intermediary approach between maintaining existing frameworks and adopting radical centralisation, VERE participated in this survey to propose a solution that accommodates all stakeholders. The recommendation involves incremental progress toward substantive harmonisation, beginning with the establishment of standards or minimum requirements and the alignment of various technical systems as an initial, practical step.
The primary challenge lies in harmonising categories, reporting formats, obligations, deadlines, and related elements into standardised formats, as described, for example, in the EU Competition Compass (“[…] reporting must move to digital formats based on standardised data”) or in the Draghi Report (“Measures should include requiring harmonised reporting templates […])).
At the same time, VERE considers it imperative that technical harmonisation be carried out gradually and methodically:
- Uniform data standards: EU-wide mandatory formats for categories, reporting deadlines, and data fields should be established as a first step (e.g., XML/JSON schemas, XBRL for financial reporting).
- API-first approach: National registers should become interoperable via standardised interfaces (REST APIs, OAuth2/SAML for authentication).
- Reference implementations: The provision of open-source sample interfaces by the EU would facilitate the alignment of systems.
- Measurable KPIs: Progress and the quality of implementation should be assessed using objective metrics (system availability, error rates, and processing times).
VERE e.V. therefore advocates harmonisation and digitisation in clear, manageable steps. Subsequently, the resulting simplification effects should be measured, re-evaluated, and further follow-up measures derived so that businesses, in particular, have the opportunity to adapt to innovations at a healthy pace and, above all, can benefit from simplifications in the short term or immediately. The affected companies are demanding quick results. However, these must not be complex, so as not to jeopardise acceptance. In doing so, VERE has revisited and reaffirmed its proposals from its statement on the Circular Economy Act from 6 November 2025.
VERE considers the “EU One-Stop Shop” initiative to be highly ambitious, noting that its design, development, and implementation entail significant expenses and require substantial time commitments. System maintenance, security, and development incur major outlays. The resulting costs would have to be borne collectively by all participants, and it seems questionable whether this would achieve cost relief for individual companies. Furthermore, according to the results of a VERE analysis based on the registrations of 9,000 international manufacturers, the average manufacturer has registered 1.8 countries and 3 waste streams; thus, they would hardly benefit from an EU One-Stop Shop but would still have to help finance it.
What would the situation look like, across the EU, for the multitude of manufacturers and retailers operating purely at the national level? These entities do not need an EU One-Stop Shop and would, in turn, be burdened with costs and complexity they do not require. The only clear beneficiary of such a solution would be the online shop in a third country that ships internationally to any end consumer in the EU. Ultimately, the question arises as to who would benefit most from an EU-wide platform and who would have to co-finance the platform without deriving any benefit. Here you will find the complete VERE statement on the SME consultation regarding the Circular Economy Act.
VERE e.V. is in contact with all relevant stakeholders and keeps its members informed about further developments via the “VERE Insider”. Do not miss out and become a VERE member today!
