A Complete Guide to Understanding and Complying with Extended Producer Responsibility (EPR)
Extended Producer Responsibility (EPR) is an environmental policy approach that makes producers responsible for the entire lifecycle of their products, including design, take-back, recycling, and final disposal. EPR policies are rapidly being established as a standard practice worldwide, impacting producers with additional reporting requirements and many new challenges, especially those with operations in multiple countries. These challenges are compounded by the frequency of updates to EPR policies, which can occur as often as every quarter.
As EPR grows worldwide, producers must have the right knowledge and tools to ensure ongoing compliance with evolving policies and obligations. The purpose of this e-book is to educate readers about Extended Producer Responsibility, explain how it impacts producers in the supply chain, and provide a guide to understanding compliance obligations.
While any type of product can fall within the scope of an EPR policy, this e-book will focus on three core areas: packaging, batteries, and Waste Electrical and Electronic Equipment (WEEE) or e-waste. Legislators have identified these areas as the most voluminous and toxic waste streams.
This e-book will define Extended Producer Responsibility (EPR) and its significance for producers, address the most common challenges in EPR compliance, and provide an in-depth look at how EPR compliance works in practice. Finally, it will explain how using Source Intelligence’s EPR solution can streamline global reporting and simplify the complexities of multi-regional EPR obligations.
Extended Producer Responsibility and What It Means for Producers
Extended Producer Responsibility (EPR) is an environmental policy approach that makes producers responsible for the entire lifecycle of their products, including design, take-back, recycling, and final disposal. Rather than targeting a single point within the supply chain, EPR policies pertain to the environmental characteristics of products and production processes throughout the product chain.
The Organization for Economic Co-operation and Development (OECD) defines policies with the following attributes as EPR policies:
- The shifting of responsibility upstream toward the producer and away from municipalities
- The provision of incentives for producers to consider environmental impacts when designing products
Any type of product can fall within the scope of EPR policies, but core areas (as identified by legislators) include WEEE or e-waste, packaging, and batteries due to the volume and toxicity of these waste streams.
EPR Policies Around the Globe
While the European Union (EU) was the first to implement EPR legislation, there are now active EPR policies on every continent (excluding Antarctica). From North America to Australia, EPR policies continue to expand, impacting producers worldwide.
However, despite its global presence, EPR compliance varies not only by country but also between regions, states, provinces, etc.—from tariffs and fee structures to schedules and reporting requirements.
The Common Goal of EPR Policies
Despite variation throughout the world, EPR policies have a common goal of reducing waste, with a recent focus particularly on plastic waste, by increasing the recycling of new raw materials and, in turn, reducing the dependency on those materials.
This goal is based on the “polluter pays” principle, which is the concept that producers take responsibility for their products at their end-of-life stage. The concept encourages product design with reusability in mind and incentivizes product designs that boost recyclability and minimize environmental impact.
Producer Criteria Under EPR
Any business that manufactures, imports, sells, or brand-owns any product or packaging in an area with an active EPR policy could be considered a producer, depending on the area’s policy. The definitions of each of these types of businesses are listed below:
- Manufacturers – Manufactures a product for sale
- Importers – Imports products
- Sellers – Sells products to end-users
- Brand-owners – Owns brand-name products that are sold/imported via third parties
Companies that meet any of the producer obligation criteria must check for EPR legislation in each country they operate in to assess their compliance obligations. Countries may also have added thresholds for businesses, such as turnover and quantity of products or packaging placed on the market.
EPR Authorization and Oversight
Authorization and oversight of EPR policies also vary by country, as authority can fall under governing bodies, product stewardships, or compliance schemes.
Defining Compliance Schemes
Compliance schemes are authorized by a governing body in their country of operation. They are intended to organize the collection, recovery, and recycling of waste data requirements on behalf of producers that are members of the compliance scheme. Members then pay a fee to the scheme based on product waste type and the quantity placed on the market.
Advantages and Disadvantages of Compliance Schemes
Utilizing a compliance scheme over self-compliance (when permitted) is advantageous due to the scheme’s in-depth knowledge of reporting requirements in their district. Furthermore, if there are multiple compliance schemes within a country, they can operate like an open market, allowing producers to shop around for the best services and rates.
The main disadvantage of becoming a member of a compliance scheme is that, since schemes have a personal stake in ensuring data is accurate (for legal, financial, and reporting purposes), they often require more complex data from producers.
Some countries allow producers to report directly to the country’s governing body, which is referred to as self-compliance. However, some situations require producers to conduct EPR reporting via a compliance scheme. For example, under Germany’s EPR batteries policy, producers must utilize a compliance scheme for reporting.
Challenges of EPR Compliance
Due to differences in EPR policies around the globe, EPR compliance is complex and resource intensive. Compliance professionals often deal with the following challenges:
Collecting Quality Data from Suppliers
As producers typically do not have access to all the product data within their supply chain, they must rely on their suppliers to provide it before matching it with their sales data to generate reports. Contacting suppliers is not always a straightforward process, and some suppliers may not agree to provide the data when asked.
Preparing Reports for Differing Reporting Requirements
There are different requirements or categories for EPR reporting worldwide, which can be overwhelming for businesses with operations in multiple countries.
Tracking Changes to Policies Around the Globe
EPR legislation changes frequently, and compliance teams often struggle to keep up. This makes it challenging for producers to follow updated reporting requirements and leaves them at risk of non-compliance.
Discover more about EPR obligations
You’ve just explored what Extended Producer Responsibility (EPR) entails, its significance for producers, and common challenges faced by companies. Next, the e-book delves into what EPR compliance looks like in practice and provides an in-depth look at how Source Intelligence’s EPR solution simplifies multi-regional obligations.
Read the complete e-book for guidance on navigating the complexities of EPR.