We\u2019ve been talking about the circular economy for a long time \u2013 but there\u2019s still a way to go before it becomes a reality. Principally, one main barrier to creating a circular economy is the cost of more environmentally friendly products \u2013 especially as countries around the world face ongoing financial challenges.<\/p>\n\n\n\n
Enter Extended Producer Responsibility (EPR): an environmental policy approach in which a producer\u2019s responsibility for a product is extended to the post-consumer stage of a product\u2019s life cycle [OECD<\/a>]. Essentially, it shifts financial responsibility for a product\u2019s waste management away from taxpayers, and towards producers \u2013 which also incentivises the design of more circular products.<\/p>\n\n\n\n As this concept has become more we established what best practice looks like for EPR in the EU popular in recent years, Eunomia has been at the forefront of recommending how EU member states, industry bodies, and organisations create and implement EPR schemes. Our expertise has been vital to overcome some major challenges along the way.<\/p>\n\n\n\n Until recently, the design and the effectiveness of EPR schemes varied hugely across countries and sectors \u2013 and bodies like the European Commission recognised that this needed to change. By bringing together a team of Eunomia\u2019s policy experts, , on behalf of our client the European Commission, and developed the principles for a truly effective EPR scheme \u2013 recommendations which have since been widely cited.<\/p>\n\n\n\n We have since carried out similar work with a focus on the textiles industry for Changing Markets Foundation and the European Environmental Bureau, Policy Hub, and DEFRA. With EPR firmly on the agenda as we strive for a truly circular economy, we will continue to build and share our EPR expertise.<\/p>\n\n\n\n While EPR had for years been widely applied for packaging and a range of product types across EU Member States \u2013 from electricals and electronics to batteries \u2013 the design, and thus the effectiveness of the EPR schemes varied hugely.<\/p>\n\n\n\n That\u2019s why in 2018, Article 8a was introduced to the EU Waste Framework Directive. It set out a number of minimum requirements for EPR schemes, to ensure that:<\/p>\n\n\n\n <\/p>\n\n\n\n As Member States have flexibility in how they meet the requirements of a Directive, our clients the European Commission identified a need to publish guidance to ensure Article 8a and its commitment to a more circular economy was followed through in practice. Through a competitive process, Eunomia was selected to develop recommendations for guidance.<\/p>\n\n\n\n Our first step was to bring together a team of policy experts who could look at existing approaches applied in EPR schemes, and understand their relative strengths and weaknesses, and identify elements that might be considered to represent best practice. As part of this we engaged with a wide range of stakeholders including producers, EPR schemes, recyclers, Member State representatives and NGOs to gather their views on existing practices.<\/p>\n\n\n\n We then worked to develop a set of core underpinning principles for effective EPR. In this, we put considerable focus on two things: firstly, the importance of harmonisation across Member States \u2013 to minimise the administrative burden for producers operating in multiple countries, especially smaller producers with fewer administrative resources.<\/p>\n\n\n\n Secondly, we focused on maximising the potential effectiveness of fee modulation. We argued that aligning producer reporting requirements and frequencies would make for a solid foundation for change, while also tackling the problem of \u2018free-riding\u2019 \u2013 where producers avoid the required fees. This is a particular issue with online and distance sales, often from outside the EU.<\/p>\n\n\n\n Next, we conducted a wide-ranging review of existing and potential criteria for fee modulation and developed reasoned explanations as to which should be applied and how.<\/p>\n\n\n\n Sharing these principles and our draft recommendations with stakeholders at the EU Commission, we developed a final report and recommendations for guidance. These recommendations were published in 2020, and have since been widely cited.<\/p>\n\n\n\n Since the recommendations were published, there has been significant interest in enhancing EPR schemes from industry and policymakers across Europe \u2013 which we were well placed to advise on.<\/p>\n\n\n\n In 2022, we were tasked by Changing Markets Foundation and the European Environmental Bureau to conduct a study<\/a> on the role of EPR in driving a circular economy for textiles. We used the extensive knowledge we had already gained to make targeted recommendations for the application of EPR (and other policy instruments) to the textiles sector.<\/p>\n\n\n\nThe challenge<\/h2>\n\n\n\n
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