European Tyre and Rubber Manufacturers’ Association (ETRMA) in Brussels further reports that industry sectors affected by EPR are i.e. packaging, batteries, WEEE and tyres respectively represented by Europen, EPBA, LightingEurope and ETRMA. The recommendations have additionally been endorsed by AIM, the European Brands Association.

Extended producer responsibility means the producer’s full or partial operational and/or financial responsibility for a product extended to the post-consumer state of a product’s life cycle, as a means for Member States to meet EU collection, recycling and/or recovery targets.

A strengthened EU regulatory framework for EPR aims to support EPR obligated industries and the Member States that apply EPR as an end-of-life tool to help reach related national and EU targets. Improved implementation, enforcement, accountability of all actors involved in EPR implementation, along with EU minimum performance requirements (see attached) will help ensure a level playing field for all EPR schemes and promote a viable market for secondary raw materials. In view of the forthcoming Circular Economy proposal, the co-signatories seek to correct market failures by calling for a strengthened EPR regulatory framework in EU legislation.

“Our common requirements are valid across the different waste streams and EPR compliance models in Europe.” said Virginia Janssens, Managing Director of Europen. “However, where appropriate, these common rules will need to be complemented with sector specific EPR legislation addressing our specific market challenges and supply chains structures. For instance, EPR and its implementation will also need to be embedded in the Packaging and Packaging Waste Directive, respecting the lifecycle approach and the Internal Market principle”, Ms Janssens stressed.

Hans Craen, Secretary General of EPBA, states that “in particular in light of the current discussions on circular economy, it is an opportune moment to discuss and move forward with common EU minimum requirements for extended producer responsibility.” He added that “these common minimum requirements for EPR will form a good basis for Member States in implementing a more coherent producer responsibility framework for the collection of portable batteries”.

“Transparent and accurate reporting of EPR schemes is necessary to ensure non-discrimination, cost efficiency and flexibility”, said Fazilet Cinaralp, Secretary General of ETRMA. “This includes transparency of material flows, costs, tendering procedures, geographical scope and overall financial solidity. For transparency reasons, the environmental fee paid when buying a new tyre should be visible to the buyer as separate line item on their invoice and be reflected through the entire supply chain”. She further stressed that “consumer engagement and participation is a pre-requisite to the success of any EPR scheme. In the case of tyres, this should not only cover consumers but also professionals that are mounting and dismounting the tyre.”

“LightingEurope believes that EPR can be a very effective way of enhancing a more circular approach. But, without consistent implementation, environmental outcomes are diminished, and a level playing field is compromised.“ stated Zoltan Pilter, Chair of the association‘s collection and recycling working group.

Additional and individual waste stream positions on EPR and/or the Circular Economy can be found on the respective websites of the co-signatories.


The signing organisations

Europen is the European Organization for packaging and the Environment.

ETRMA is devoted to advocating the interests of the tyre and rubber manufacturing industries with the European Union Institutions and other international organizations.

EPBA ist he the European Portable Battery Association (EPBA), the authoritative voice of the portable power industry.

LightingEurope is an industry association representing leading European lighting manufacturers, national lighting associations and companies producing materials.

AIM is the European Brands Association. AIM’s membership comprises corporate members and national associations that have a similar but more local constituency. Members are primarily manufacturers of branded products in fast moving consumer goods.