Critics Under EPR (Extended Producer Responsibility), in Europe, anyone who manufactures or sells an item must pay for and take responsibility for what happens to that item when it becomes waste. This concept is gaining ground worldwide, and it is important to understand its prospects, limitations, objectives, and challenges. We explore this in this article
by Massimiliano Viti
Time, money and regional harmonisation. These are the three key elements in the fight against the uncontrolled growth of waste, particularly textile waste, which, according to studies, is set to increase by over 40 per cent by 2035. Yet less than 1 per cent is currently recycled. All the rest is incinerated, sent to landfill or abandoned. To prevent this forecast from becoming a reality, Europe has introduced a series of regulations. Ranging from mandatory separate collection of textiles to a ban on the destruction of unsold products, right through to EPR (Extended Producer Responsibility). Under EPR, anyone who manufactures or sells an item must pay for and take responsibility for what happens to that item once it becomes waste. This is a concept that is gaining ground worldwide.
An overview of Extended Producer Responsibility
Some European countries, including France and the Netherlands, already use Extended Producer Responsibility (EPR) schemes for textile products. The EU, however, requires these to be implemented across the entire EU by January 2028. The first obvious obstacle is the lack of harmonisation. In other words, each Member State is responsible for managing the directive independently and has its own producer responsibility organisation (PRO), its own registration procedure and so on. Consequently, if a manufacturer, importer, brand owner, retailer or e-commerce company sells in several EU countries, they must register and pay contributions in each individual country.
Germany and Italy
In Germany, the two largest trade associations in the textile and retail sectors have launched a joint lobbying campaign to demand a greater say in defining how the new EPR system is implemented. In Italy, at the end of July, the Unified Conference approved the draft regulation that will establish EPR for the fashion supply chain. The measure introduces a comprehensive system for managing the end-of-life of products. Promoting separate collection, reuse, repair and recycling, with the aim of strengthening the circular economy and reducing the sector’s environmental impact. The legislationals incentivises eco-design, rewarding products that are more durable, repairable and made from recycled materials.
Operational challenges
Operational challenges remain across Europe, most notably the lack of dedicated infrastructure for collection and recycling. According to estimates compiled by ReHubs and BCG-Boston Consulting Group (and contained in the report “Advancing textile circularity: Europe’s textile waste challenge’), between 8 and 11 billion euros of investment would be required to achieve a 15 per cent textile recycling rate by 2035 (i.e. recycling 2.7 million tonnes of post-consumer waste and collecting 8 million tonnes of materials). “Extended producer responsibility (EPR) must be harmonised to make it simple and manageable,” Robert van de Kerkhof, CEO of ReHubs, told Reuters. “Investments must be coordinated in such a way as to ensure sufficient capacity throughout the value chain.”
The PPWR Regulation (Packaging and Packaging Waste Regulation)
Brussels is seeking greater legislative harmonisation through the PPWR (Packaging and Packaging Waste Regulation). The PPWR and EPR are two complementary pillars of European policy on the sustainable management of packaging, with the former representing the binding regulatory and technical framework, whilst the latteris the economic instrument for ensuring accountability. Since 12 August, it has been compulsory to display the PPWR (Packaging and Packaging Waste Regulation) (for both empty and filled packaging), which certifies compliance with the sustainability and safety requirements laid down by European legislation. Whilst it is true that some packaging requirements are more standardised, this has not led to the establishment of a single EU-wide EPR register for packaging.
Some critics
The measure has drawn considerable criticism from small business owners, whom the legislation places on an equal footing with large companies suchas Amazon, Shein and Temu. It is no coincidence that Gramta– the platform for EPR and PPWR packaging compliance for EU sellers – has already highlighted that some companies are suspending or withdrawing from the EU market when sales are limited due to significant packaging obligations and costs, there by favouring the dominance of large corporations.
United States: a regulatory patchwork
In the United States, too, EPR is not regulated by a single federal regulatory framework, but is developing through a set of law sspecific to each individual state, with differing definitions, timelines and compliance requirements. This legislative patchwork risks becoming unmanageable. For example, a company might be subject to regulation in one state, exempt in another, and subject to different definitions and deadlines in a third. All this comes with the risk of rather hefty penalties in the event of non-compliance.
The case of Vietnam
Vietnam is also reviewing its EPR policy. According to Tang The Cuong, Director of the Environmental Authority at the Ministry of Agriculture and Environment, EPR should not be viewed simply as a financial obligation. Instead, it should encourage businesses to redesign their products – that is, to choose suitable materials, organise collection and recycling, and invest in circular economy solutions. In Asia, they are well aware that there is no one-size-fits-all EPR model. The system must reflect each country’s institutional framework, market conditions and recycling capacity.
Photo Shutterstock
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