Based on the evidence that after years of implementation Extended Producer Responsibility has not actually been so extended, ACR+ member ENT Environment & Management published an opinion on generalised extended producer responsibility (GEPR) supporting the implementation of the concept of GEPR, whereby all products put into the market, and likely to become waste at some point, would be subject to producer responsibility.

According to ENT the implementation of GEPR would entail a huge additional burden of paperwork and the need of additional data on impact and cost of the different waste streams. However, this would be less burdensome, faster and cheaper to regulate and monitor than the never ending process of creating one new EPR scheme after another. This would also ensure a consistent application of EPR across a range of different products, which is lacking amongst the different existing EPR schemes.

According to ENT many details would need to be discussed (links among existing EPR and new GEPR schemes and the corresponding PROs, legal nature, compatibility with other economic incentives, etc.). However GEPR could generalise incentives towards recyclability and cleaner production and would suppose a much fairer distribution of costs, shifting them from Public Administrations to producers, and ultimately from taxpayers to consumers.


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