In a joint statement, the organisations, including EURATEX and Eurocommerce, said the legislation should move Europe away from “fragmented” waste management and towards a “functioning internal market” for secondary raw materials. EPR is used across the EU to finance waste collection, sorting and recycling. However, the statement said performance remains uneven between member states, with divergent national rules limiting the effectiveness of existing systems.
The industry groups want the CEA to establish a “strong, harmonised and enforceable” EU framework for EPR.
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They are calling for a directly applicable EU regulation covering EU-mandated EPR schemes and relevant waste streams, alongside sector-specific requirements where necessary.
According to the statement, common rules would reduce regulatory differences, support cross-border value chains and provide greater certainty for companies operating circular business models.
The proposed framework should be based on Article 114 of the Treaty on the Functioning of the European Union, reflecting its internal-market objective.
The coalition also wants EPR to remain “producer-led”, with producers retaining responsibility for decision-making. Public authorities should supervise the systems, but producer contributions should be reserved for waste-management activities rather than being treated as general public revenue, the organisations said.
“EPR stems from the polluter pays principle for a reason: producers should be responsible not only for financing waste management, but for organising the systems needed to collect, sort and recycle the products subject to EPR obligations that they place on the market,” the statement read.
In addition, the groups are seeking greater independence between EPR decision-makers and organisations that receive EPR funding. They want Producer Responsibility Organisations (PROs) to publish standardised annual information on performance, ownership, membership, fee structures, eco-modulation criteria, budgets and the use of producer contributions.
Transparency requirements should extend beyond PROs to public authorities, municipalities and waste operators receiving EPR funding, according to the statement.
The organisations said this would improve accountability and help assess whether contributions are proportionate and directed towards the intended outcomes.
They call for EPR funds to be ring-fenced for the product categories and waste streams for which they are collected. It said this would prevent cross-subsidisation and direct funding towards the infrastructure and operations needed to meet recycling targets.
The statement also supports consistent application of the “net cost principle”. Revenue from the sale of secondary raw materials and other recovered outputs should be deducted from costs covered by producers, while safeguards should prevent the same revenue or cost from being counted twice.
The industry groups want EPR funding to remain focused on collection, sorting, recycling infrastructure and related system improvements. They said broader waste-prevention or reuse measures should not be funded through EPR where dedicated EU legislation already applies.
The proposed legislation should also reduce administrative complexity for small and medium-sized businesses and companies operating across several member states.
For packaging EPR, the statement says member states should be able to require authorised representatives for producers based outside the EU that make products available on their markets. It opposes mandatory national representation for producers already established within the EU.
The coalition has also called for stronger requirements on “separate collection”, including reporting on waste-stream coverage, population and territorial coverage, public-awareness measures and any exemptions.
It said communication campaigns should explain correct disposal and sorting practices, the role of separate collection and how participation can support higher-quality recycling.
These measures are necessary to create the conditions for a European market for secondary raw materials, they said.
