Joint letter to the European Commission on the Circular Economy Act: Beyond waste management - EPR to finance circularity

ACR+ joined 38 other organisations (representing civil society, cities, and businesses) calling on the European Commission to reboot Extended Producer Responsibility (EPR) 

As a coalition of progressive organisations committed to building a truly circular, fair, and resilient European economy, signatories welcome the European Commission’s decision to address Extended Producer Responsibility (EPR) within the forthcoming Circular Economy Act (CEA). However, they note that focusing only on optimisation and harmonisation won’t be enough to meet the EU’s climate and circularity goals. Europe’s recycling rates have stagnated as waste generation rises.

To meet Europe’s climate, circularity, and strategic autonomy goals, on top of optimising and harmonising EPR criteria, the CEA must:

• Redefine EPR to include the full cost coverage of a product’s end-of-life treatment, including littering/clean-up costs.
• Mandate EPR tofi nance the waste prevention, repair, and reuse stages of a product’s life cycle, with the amount necessary to achieve the relevant policy goals and targets.
• Introduce binding targets for waste prevention and reuse (in addition to recycling) for the relevant product streams to be achieved with the funding of EPR schemes.
• Define the meaning of cost-coverage for non-waste-related activities (e.g, prevention, reuse, and repair) in order to delineate the limits of producer responsibility.
• Review the governance of EPR schemes not only to ensure harmonisation and oversight of PRO performance but also, in particular, where they address upstream measures, to ensure that municipalities, social enterprises, reuse organisations, and recyclers have a seat at the table in scheme design and decision-making.
• Ensure that EPR schemes include a ‘fee transfer mechanism’ to finance the end-of-life treatment of second-hand products when those are exported outside the EU.