EPR Club member ACR+ has recently released a position paper on the EU Circular Economy Act. Below, you can find their key recommendations on EPR.
ACR+ Position on the EU Circular Economy Act
“The Association of Cities and Regions for Sustainable Resource Management (ACR+) connects 89 members representing local and regional authorities. Together in their cities and regions, they lead Europe’s just transition to a competitive circular economy and the sustainable management of resources. With recognised expertise implementing circular economy measures, ACR+ welcomes the European Commission’s commitment to introduce a Circular Economy Act.
For Europe, advancing the circular economy is imperative not only for its core benefit of waste and resource-use reduction, but also as a strategic lever to boost competitiveness, rejuvenate industrial capacity, and minimise resource and import dependency. Moreover, the transition to a circular economy is an important factor for reducing pollution, protecting biodiversity, and mitigating greenhouse gas emissions.
Highlighted in his report on the future of the Single Market, Enrico Letta testified that “Circular economy is the only possibility of saving the planet and changing the paradigm of present manufacturing.” However, achieving the full benefits of the circular economy will require broad policy measures, i.e. a revision of several EU Regulations and Directives. ACR+, which has more than 30 years of experience working on material resource management, offers recommendations based on the expertise and practices of local and regional authorities across Europe, and lessons learned during EU-funded projects.
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Extended Producer Responsibility (EPR)
Since their inception, Extended Producer Responsibility (EPR) schemes have mobilised resources for separate waste collection. However, improvements to EPR are necessary to move further up the waste hierarchy by contributing to prevention and re-use. A revision of EPR schemes would help the EU transition to a circular economy that supports its industrial and environmental goals all while promoting a resource-wise approach to material use. ACR+ therefore welcomes the European Commission’s decision to address EPR within the CEA and offers the following measures for consideration.
Recommendation #10:
Redefine EPR to include the full cost coverage of a product’s end-of-life, including unsorted waste and littering/illegal dumping clean-up costs.
In an EPR system, producers’ contributions should be enough to cover the costs of running the system (administration, communication, and waste management) to meet existing targets. However, EPR fees are not always sufficient to cover all the operational costs linked to the items put on the market, which end up falling on local authorities. In addition, for most products (except SUP items) local authorities assume the financial burden linked to the clean-up, transportation, and treatment of items which are littered or illegally dumped in public spaces. Since cost coverage is dependent on capture rate, for waste streams with very different rates of collection (e.g. tires (90 %) compared to WEEE (40 %)), the cost of implementing real full cost coverage is very different. However, despite these difference, EPR systems should all aim at full cost coverage to avoid the financial burden on municipalities. As it is designed now, the system only imposes producers to cover the costs of sorted waste, which can create a conflict of interest as the less is collected, the less fees must be paid. Including the treatment of unsorted waste within the cost coverage definition would prevent this. Legislation should thus provide a clear definition of the full cost coverage principle, including litter costs for products beyond single use products.
Recommendation #11:
Mandate EPR to finance waste prevention, repair reuse and cost-coverage for these activities to delineate the limits of producer responsibility.
Current EPR systems fail to contribute to financing more resource-efficient options such as waste prevention, reuse, repair, refurbishment, or remanufacturing. This lack of support for strategies higher up the waste hierarchy partly explains the limited progress on circularity achieved in the past. The absence of specific prevention and reuse targets (except for packaging waste) further hinders this. While the EU’s new Packaging and Packaging Waste Regulation (PPWR) requires that part of the EPR budget supports prevention and reuse measures, it does not mandate a meaningful funding share. Therefore, the Circular Economy Act must mandate EPR to finance waste prevention, repair, and reuse stages of a product’s life cycle, with the amount necessary to achieve the relevant policy goals and targets. Quantified targets on prevention and reuse should also be developed. Prevention measures should include awareness-raising, lifetime extension through repair and reuse, research and innovation, and stimulation of circular business models (e.g. product-service combinations, rental schemes). For example, France has introduced the Bonus Réparation, a national repair fund financed entirely by EPR fees, which directly subsidizes the cost of repairs for electric and electronic appliances, clothing, and footwear.
Recommendation #12:
Review the governance of EPR schemes to ensure that public authorities have a seat at the table in scheme design and decision-making.
Following the partnership principle, one of the key principles of the management of EU funds, all relevant stakeholders (public authorities, civil society organisations, and economic actors and social partners) should participate in the design and implementation of EPR schemes. In addition, EPR systems should adopt a governance approach where public authorities have a key role, considering the need for control and oversight, and considering the typical waste management competence of local authorities. Although they play a key role in the implementation of EPR schemes on the ground, municipalities often feel “detached” from the decision-making process regulating these schemes. Therefore, producer organisation should better connect with the city level to understand and recognise the real costs and challenges they face.”
This article presents an excerpt from ACR+’s position paper, focusing on their key recommendations regarding Extended Producer Responsibility. Please click here to read the full recommendations.