EPR

Definition

Extended Producer Responsibility (EPR) is an approach to environmental policy whereby the producer of a product must take financial or physical responsibility for the post-consumer stage of a product’s lifecycle. This is achieved by extending the traditional stages of production, delivery and sales to include collection, sorting and recycling or disposal.

Principles

EPR schemes adopt a ‘producer pays’ principle to encourage environmental responsibility by either economic disincentives (such as landfill tax or incineration fees) or by shifting industry attitudes to encourage private investment into recycling technologies. 

To date, EPR has generally been applied to products commonly disposed of in public or household waste that is managed and paid for by local governments. These bodies frequently have a legal obligation to collect, maintain and dispose of consumer waste regardless of what it is or how much of it there is. This is a significant burden on the public purse and UK taxpayers cover around 90% of the costs of disposing packaging waste created by private businesses.¹

With most post-consumer waste materials, the cost of collecting, sorting and recycling can often be greater than revenue made from the sale of the resulting recycled materials.² EPR law has been proven to generate the funding required to address this imbalance, or ‘full net cost’ by moving the burden from taxpayers and local government to brands and retailers while simultaneously incentivising manufacturers to reappraise their use of polluting materials through reduction or elimination.³

An EPR measure known as ‘eco-modulation’ incentivises product innovation by reducing financial penalties on items that are easy to recycle, that contain recycled material or that have been designed for better durability.⁴ Eco-modulation also promotes rules for product labelling that provides end-of-life guidance and clarifies the material’s provenance. This is seen across packaging produced for the French market since the introduction of the now familiar ‘Triman’ logo and accompanying ‘Info-tri’ guidance. The country’s 2022 introduction of the Anti-Waste & Circular Economy Law means product packaging must now display uniform guidance indicating how a product or its packaging components should be sorted, recycled or disposed of by consumers.⁵

Implementation

Countries such as France and Sweden have used EPR for several decades to cover a wide number of products from textiles and tyres to gardening equipment and toys. As part of their eco-modulation measures, the French government introduced a mandatory ‘Indice de réparabilité’ (repairability index) in 2021, applied to a number of household products such as vacuum cleaners, washing machines and dishwashers. Items for which spare parts and repair information are available are subject to lower fees than those without and the index also includes ratings on the ease of disassembly.⁶ The directive aims to influence and incentivise less wasteful design and manufacturing processes, while eco-modulation fees are used to lower the cost of repairs by financing repair vouchers for consumers.

The UK introduced its first fully-fledged EPR scheme in 2025, targeting businesses that place packaging onto the market. Producers are be required to audit and report their packaging production to the environmental regulator for materials such as paper, plastic, aluminium, steel and glass.  

The UK is also looking to incorporate a mandatory disposable coffee cup ‘take-back’ scheme. Current estimates indicate that this single item represents nearly 50% of the fibre-based packaging market, with as many as 2.5 billion cups disposed of every year in the UK alone.⁷ For the UK, the textiles industry has been highlighted as the next priority area for EPR.

Some industry reports have reacted to the proposals around EPR with the suggestion that new costs may simply be passed on to the consumer,⁸ while other critics argue that past measures to reduce packaging volumes have encouraged a ‘light-weighting’ strategy (where packaging is redesigned to lose weight by eliminating unnecessary elements and lowering the overall volume of materials), which potentially increases the use of light plastics or films, which are harder to recycle.⁹

Following a delayed launch of the UK packing EPR, industry news outlet The Grocer reported that industry groups welcomed a watering down of plans to make businesses pay more towards the cost of recycling and litter, and pushed for ‘overly prescriptive’ Extended Producer Responsibility schemes to be delayed in the UK.¹⁰

In contrast, climate-action charity WRAP have stated that ‘Extended Producer Responsibility will play a vital role in shifting to a circular economy. EPR is a proven method to get brands and retailers to take responsibility for the whole value chain of their products, including what happens to them after they get disposed.’¹¹