updated the 28.04.2025
Understanding the Extended Producer Responsibility
The EPR is an environmental policy approach, meaning it serves as a guiding principle for shaping legislation rather than being a single regulation in itself. It shifts the responsibility for the environmental impacts of products, particularly in their post-consumer phase, from public authorities to the producers. This includes responsibility for the collection, sorting, reuse, recycling, and disposal of products and materials after use. The aim is to promote more sustainable product design, reduce waste, and support the development of a circular economy.
In the EU, EPR is implemented through various legislative acts. The most relevant frameworks include the Packaging and Packaging Waste Directive and its upcoming replacement under the Packaging and Packaging Waste Regulation (PPWR), as well as the proposed revision of the Waste Framework Directive which will introduce mandatory EPR schemes for textiles. Member States are responsible for transposing these frameworks into national law and defining the operational details, such as registration procedures, reporting obligations, and fee structures.
Denmark’s new packaging EPR regulation will come into force on 1 October 2025, and companies operating in this area should already be preparing for compliance. The textile EPR, on the other hand, has only been proposed at the EU level as part of the revision of the Waste Framework Directive. While some Member States like France have already introduced national textile EPR schemes, a harmonised EU-wide approach is still under discussion. Once the legislation is adopted, Member States will have 18 months to transpose it into national law.
Does the Extended Producer Responsibility affect your company?
While the core principle of Extended Producer Responsibility applies across product types, the specific rules and obligations vary depending on the sector and material. This means that packaging, textiles, and other regulated categories each have different compliance systems, reporting structures, and timelines. For packaging in particular, most EU countries already have established national schemes in place, and companies are already required to comply.
Because of this, the current focus for many businesses is on packaging. Yes. All companies placing packaging the EU market must comply with EPR requirements, regardless of size. Whether you manufacture, import, or sell under your own brand, you will need to register with the national EPR scheme(s), report data on the packaging you introduce, and pay relevant fees. This also includes online retailers and companies outside the EU selling into EU countries. EPR does not distinguish between company types when it comes to responsibility - if your product creates packaging waste, you're in scope.
How to work with the Extended Producer Responsibility?
It’s also a good time to evaluate your packaging and material choices with waste reduction and recyclability in mind. Some Member States offer fee reductions for more sustainable packaging, such as materials that are recyclable or contain recycled content. Ensure that your suppliers and logistics partners are aligned with your EPR obligations so they can support your compliance across the full value chain.
How is the Extended Producer Responsibility connected to other initiatives, regulations and laws?
EPR complements other major EU sustainability initiatives. It aligns with the Corporate Sustainability Reporting Directive (CSRD) by generating environmental data that feeds into ESG reporting, especially around waste and circularity. It also supports the goals of the EU Green Deal and the Textile Strategy for Sustainable and Circular Textiles, which aim to increase reuse, reduce landfill, and drive sustainable product design.
The implementation of EPR is directly tied to the Packaging and Packaging Waste Regulation (PPWR) and the Waste Framework Directive, which form the legal backbone for packaging and textile-related responsibilities. The PPWR aims to harmonise packaging rules across the EU and promote recyclable, reusable, or compostable packaging. Meanwhile, the revision of the Waste Framework Directive is expected to introduce clear, mandatory EPR schemes for textiles, helping to standardise how textile waste is managed and funded across Member States.