In line with the upcoming Circular Economy Act, the PRO Circularity Alliance has published a position paper advocating for a Central European EPR Register to harmonize national EPR systems, reduce compliance costs, and improve transparency across Europe.
Right now, the Alliance argues, Member States operate their own separate EPR systems, which are often further fragmented by waste streams. This results in multiple registers across the EU as national authorities are required to set up their own IT infrastructure, and each requires finances to be developed and maintained.
Furthermore, producers are expected to register separately across national and stream-specific systems – each with their own interfaces and information requirements, and not always available in multiple languages.
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.
The outcome is expected to place a disproportionate burden on cross-border operators and SMEs and disrupt the smooth functioning of the European market.
“This is not a marginal issue,” the paper argues. “EPR affects millions of producers across virtually all consumer-facing sectors.
“Where compliance becomes unnecessarily complex, cross-border trade suffers — and where compliance is difficult and time-consuming, non-compliance becomes more attractive.”
In response, the PRO Circularity Alliance calls for a structured policy discussion regarding a Central European EPR Register. Apparently, this would comprise a shared administrative and digital infrastructure to exchange data between producers, PROs, and national authorities.
The register is expected to offer producers operating in the EU a single point of registration, featuring a harmonized structure and layout alongside standardized formats for data submission and reporting. This is set to be applicable across Member States and their waste streams.
The approach is believed to cut down on administrative burden and costs for all participants; lower barriers to compliance and market participation; improve data quality and transparency across Europe; and strengthen measures to prevent free riding.
The Alliance emphasizes that a Central European EPR Register would not replace national EPR systems, but instead support them through a shared digital infrastructure. It offers its own services to help design workable solutions, provide practical expertise, and engage constructively in implementing discussions.
This Register comes in the context of recent discussions about the EU’s Single Market and the broader European economy. At last month’s European Industry Summit in Antwerp, industry players called for harmonized rules, investment-ready frameworks, and the stronger enforcement of rules to prevent unfair trade practices.
Calvin Lakhan, director of Circular Innovation Hub at York University’s Faculty of Environment and Urban Change, has also spoken to Packaging Europe about rising programme costs and declining recycling rates across Canadian provinces – arguing that EPR frameworks ‘remain focused on transferring financial responsibility rather than driving systemic transformation’.
In other news, CITEO announced in January that it had joined the Extended Producer Responsibility Alliance, which intends to strengthen a strong, coordinated non-profit EPR model at the European level.
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