The upcoming Circular Economy Act must address ‘wide’ performance gaps between national packaging EPR systems across the EU, according to a study commissioned by EUROPEN and conducted by CIRCPACK by Veolia.
With the Packaging and Packaging Waste Regulation (PPWR) enforcing binding recycling targets and harmonized reporting requirements across the EU, EUROPEN highlights the importance of meeting recyclability-at-scale requirements to secure continued market access to secondary raw materials.
Yet it also argues that national EPR systems must successfully collect, sort, and recycle packaging at scale in order to meet the PPWR’s requirements.
Gaps in infrastructure are considered a ‘major’ barrier to recycling at scale, with sorting and reprocessing capacity described as ‘insufficient’ across most of the EU. The study warns that targets alone will not unlock circularity across the bloc, and that investment in collection, sorting and recycling systems is also required.
Governance quality matters more than the governance model, EUROPEN suggests. Whether the system operates under a single producer responsibility organization (PRO) or multiple, the study argues that clear responsibilities, strong oversight, robust reporting and effectively tracked financial flows are the most important factors.
Furthermore, data granularity and transparency are expected to help market operators identify where material is being lost, where investment is required, and whether fees are being used effectively. Conversely, the absence of transparent and comparable data is thought to make it harder to identify and address weak points in the supply chain.
Additionally, the report indicates that granular, eco-modulated fee structures that differentiate by material, format and recyclability perform better than flat or basic fee models.
EUROPEN asserts that these findings should directly inform the preparation of the Circular Economy Act.
“The CEA should help move Europe beyond fragmented national approaches by establishing a more harmonized and effective framework for EPR, through a dedicated EU EPR Regulation,” the company says. “It should strengthen governance and transparency, support more comparable and granular reporting, promote eco-modulation, and help ensure that producer contributions are directed to the collection, sorting and recycling infrastructure needed to meet Europe’s circularity objectives.
“Just as importantly, it should recognize a basic principle: EPR must remain focused on its core purpose - organising and financing effective waste management, and deliver EU’s recycling objectives. If Europe wants a genuine market for secondary raw materials, it needs systems that perform on the ground.
“CIRCPACK’s new study makes one point unmistakably clear: the best-performing systems already show what works. The challenge now is to translate that evidence into an EU framework capable of lifting performance across all Member States. The Circular Economy Act is the opportunity to do exactly that.”
This is the latest statement in an ongoing conversation around the Circular Economy Act. Earlier this year, EUROPEN joined Metal Packaging Europe, FINAT and Cepi in signing a statement calling for the Act to be grounded in an internal market legal basis – describing the EU’s waste management landscape as ‘fragmented’ due to divergent national regulatory frameworks.
Businesses like IKEA and LEGO also asked the European Commission to secure a Single Market by aligning regulatory requirements in an ‘ambitious’ Circular Economy Act and allowing circular solutions to scale up.
EUROPEN went on to join the call for a digital one-stop shop to introduced under the CEA in order to implement EPR across the bloc, while the Roundtable for Reusable Containers, Trays and Pallets has urged policymakers to recognize reusable transport packaging as a key pillar to achieving the Act’s sustainability goals.
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