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EPR Club debate on harmonisation of EPR registries and free-riding

On 23 June, the EPR Club hosted a debate on harmonisation of registries and free-riding, in collaboration with the LIFE 4EPR project

The event brought together EPR experts and practitioners to discuss key challenges and opportunities in the implementation of Extended Producer Responsibility (EPR) schemes, with particular focus on harmonisation, registration and freeriding. 

The first part of the discussion focused on the harmonisation of EPR registries at EU level to streamline product registration and fee reporting across markets. The LIFE 4EPR partner ENT presented the concept of unified registries elaborated in the context of the project, under the name of Registration and Reporting Gateaway (RRG). The RRG includes three key modules or sections: 

  1. the EPR information Hub, to be fed with info from national registries;
  2. the Producer registration section, where national registration authorities check and validate producers’ registrations and issue a unique registration number (URN);
  3. the products reporting section, where producers report the products put on the market following either a single entry data route or a national register route. 

The RRG was built integrating feedback and inputs from EPR practioners and experts, provided during consultation sessions held from January to June 2026. The next phase of the project involves the development of a digital mockup based on the concept elaborated. 

The second part of the discussion focused on the issue of free-riding, and on strategies to address them: Alexander Goldberg from EAR (WEEE German Register) presented the German approach to tackling free riding in the WEEE sector, through the obligation for online sellers to verify the registration of their costumers, introduced in 2022. Moreover, since 2015 producers selling WEEE products that are not based in Germany are obliged to appoint an authorised representative in the country, which has led to greater fairness in competition. The two regulatory initiatives above have proven very effective in tackling free riders not established in Germany. 

Anissa Hamroun from CITEO (French packaging PRO) shared about the current registration process for producers in France and about CITEO’s responsibility when it comes to free riding, including the actions performed by the PRO to increase awareness among producers on reporting and registrations’ obligations. 

Hamroun also shared the process to be followed in case of non-compliant producers, and about the challenges faced by the PRO for identifying these and ensuring they are sanctioned by the relevant authorities. 

The debate provided a useful opportunity for representatives of different EU member states and sectors (producers, registries) to come together and discuss key challenges and opportunities for further harmonization of registration and reporting obligations, and how to tackle more effectively the issue of free riding across the EU. 

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