This development, observed in several EU Member States, threatens to undermine the foundational principles of EPR systems, which are crucial for the region’s circular economy framework, said the coalition.
The industry groups, including E-commerce Europe, EURATEX, and the Global Fashion Agenda, among others, emphasise that EPR systems should remain producer-driven, transparent, and accountable, as mandated by Article 8a of the Waste Framework Directive.
They argue that harmonisation across the EU is vital to maintain a functional Single Market and to minimise administrative burdens.
Furthermore, a clear delineation of roles between regulators, supervisors, and operators is essential to prevent conflicts of interest and ensure good governance.
Recent shifts towards assigning PRO functions to state-owned or controlled bodies have raised alarms. Such models, already seen in waste streams like packaging and batteries, risk diluting the core governance principles of EPR if roles are not distinctly separated.
The industry warns that when the state assumes multiple roles as regulator, supervisor, and operator, it can lead to reduced transparency, limited accountability, and the potential misuse of EPR fees as public revenue rather than targeted funding.
The design of PRO models has significant implications for investment and financing. Predictable governance structures and transparent fee-setting mechanisms are crucial for attracting private capital necessary for waste management infrastructure.
Conversely, state-run models may deter investment due to perceived fiscal risks and unclear reinvestment strategies.
The industry coalition calls for a coherent, predictable, and harmonised approach to EPR across the EU.
It urges policymakers to ensure that EPR systems remain producer-driven, a one-stop shop for registration and reporting and avoid state-run models that could fragment the Single Market and weaken governance.
Maintaining a clear financial separation between EPR fees and public budgets is essential to uphold transparency and trust, the coalition suggested.
The undersigned organisations stand ready to collaborate with European institutions and Member States to safeguard effective, harmonised, and producer-driven EPR systems that support circularity and environmental integrity.
