We were commissioned by Ecommerce Europe to review the administrative burden that fragmented EU Extended Producer Responsibility (EPR) measures place on businesses and examine the potential for ‘one-stop shop’ tools to help overcome complexity.
EPR is a powerful tool for regulators, and ensures producers pay the costs of dealing with their products at end-of-life. In the EU, EPR is required for a range of products, but provided they meet essential requirements, Member States have discretion over exactly how schemes are established. This fragmentation can make navigating requirements difficult and time-consuming for businesses operating across the Single Market.
Our research focused on three business-to-consumer product streams subject to EPR, namely packaging, batteries, and waste electrical and electronic equipment (WEEE) across France, Germany, Spain, Italy, Netherlands, Belgium, and Luxembourg.
We found EPR fragmentation causes administrative burdens and demands significant staff time, cost and resourcing for producers at four key stages of compliance, including:
- Understanding obligations and keeping up to date with legislative requirements
- Registration for every country and product stream
- Reporting requirements that vary between product streams and Member States
- Producer fee approaches
We concluded that a one-stop shop EPR platform could help reduce the administrative burden for businesses in relation to understanding obligations, registering, reporting, and payment. However, a one-stop shop cannot be expected to solve every issue encountered due to challenges such as software gaps, ensuring legal and fair collection and distribution of payments, and the underlying lack of harmonisation in the underlying national requirements. This final factor is also a common topic in our wider work, though not the focus of this study.
