Transparency, governance and design influence a waste management system’s recycling performance more than high producer fees or specific EPR models, according to a study commissioned by EUROPEN.
Conducted by Veolia’s CIRCPACK research unit, the study covers all 27 EU Member States – highlighting the factors that differentiate EPR systems already on track to meet the Packaging and Packaging Waste Regulation’s targets for 2035 and 2035, versus those with further to go.
The analysis focuses on four key pillars: minimizing material losses, circular reporting and monitoring, creating circular markets, and transparency. These are supported through case studies in Belgium, Italy, Spain, Germany, and Hungary alongside Eurostat data, Producer Responsibility (PRO) reports, national waste registries, and format-specific recycling datasets.
The results suggest that transparent, well-governed and data-driven EPR systems that differentiate fees by packaging material, formats, and recyclability – rather than applying flat or weight-based fees – are among the most successful.
Countries that provide detailed, publicly available reporting systems and format-level data are believed to achieve higher recyclability rates than those taking more aggregated reporting approaches, especially in light of the Regulation’s incoming reporting requirements.
No single EPR governance model is found to be inherently superior to another. Instead, the study asserts that strong governance – clear regulatory frameworks, transparent reporting, and effective oversight – can achieve the desired outcome, regardless of whether the system operates through a single PRO or multiple.
“The study demonstrates that the strongest-performing EPR systems are those built on transparent governance, robust data and well-designed incentives,” said Francesca Stevens, secretary general of EUROPEN. “As the European Commission prepares the Circular Economy Act, these findings provide valuable evidence on the design features that can help strengthen EPR systems and improve recycling performance across the EU.”
Member States using format-specific fee structures are said to achieve ‘significantly’ higher packaging recycling rates – but higher fees alone are not expected to improve recycling performance unless revenues are transparently directed towards collection, sorting, and recycling infrastructure.
Infrastructure is considered a major barrier in achieving the Packaging and Packaging Waste Regulation’s recyclability-at-scale requirements, with flexible plastics, composite beverage cartons, and several other packaging streams facing challenges with collection, sorting, and reprocessing.
The study indicates that no packaging categories are on track to meet the targets across all 27 Member States. To achieve the Regulation’s recycling-at-scale objectives for 2035, Member States are encouraged to undertake ‘substantial’ investments in waste management infrastructure and improve both packaging design and EPR governance.
Additionally, the study identifies ‘significant’ gaps in data infrastructure and methodology harmonization across the EU, which could have implications for reporting requirements.
The Waste Framework Directive requires PROs to publish their fee schedule, scheme ownership and membership, and the procedure used to select waste-management operators. It does not require them to disclose how aggregate fee revenue is allocated downstream, which the study considers to be the ‘largest visible gap’ in the current EPR transparency framework.
Looking ahead, the study calls for Member States to develop EPR systems with transparent methodologies and governance, consolidated operational responsibility, granular eco-modulated fee structures, and format-level data collection and reporting. This is expected to be more effective than spending more money on less efficient systems.
The upcoming Circular Economy Act is considered to be an opportunity to strengthen EPR governance, transparency, and reporting requirements across Europe.
EUROPEN was recently among the signatories of a joint statement calling for the European Commission to introduce a digital One-Stop Shop for EU-wide EPR implementation into the Circular Economy Act. This single ‘point of entry’ for all mandated EPR schemes is expected to ease the administrative burdens on companies and authorities alike.
This came after the PRO Circularity Alliance published a position paper calling for a Central European EPR Register to harmonize national EPR systems, reduce compliance costs, and improve transparency across Europe. Multiple national and stream-specific registers are thought to cost ‘unnecessary’ amounts of money for technical setup and administration, increase complexity without delivering any additional environmental value, and create general administrative burden that could otherwise be avoided.
A report from the Alliance to End Plastic Waste also argued that EPR is an essential factor in improving recyclability rates for flexible plastics. EPR schemes are anticipated to boost end-market demand for recyclable material and incentivize investment across the supply chain, while eco-modulated EPR fees could encourage producers to adopt simple, cost-efficient and recyclable packaging designs.
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