Have you ever experienced problems with Extended Producer Responsibility (EPR) in the EU? Ever wished the EU would simplify the EPR compliance journey? Ever thought about the efficiency gains associated with EPR registration, reporting and even payment – all taking place on one, single, digital platform accessible anywhere in the EU?
If you answered “yes” to at least one of the questions above, this article is for you. You are about to find out how a group of organisations is working together and deliver a concrete proposal to tackle the concerns mentioned above.
EPR compliance in the EU: what is the problem?
EPR compliance in EU Member States is affected by multiple shortcomings. Producers subject to EPR rules flag difficulties in understanding their obligations, point out challenges in making sense of registration processes, and have uncertainties about which data to provide for reporting. For example, information about obligations that apply to a company’s business model or set of products offered are scattered between national and EU legislation. Also, joining an official register can occur via one or multiple channels (a register and/or a Producer Responsibility Organisation, short PRO), and data for reporting purposes can refer to current or past products made available on the market.
But this is not all. When a producer must comply with multiple EPR schemes – for example, because their packaged laptop is subject to three EU-mandated EPR schemes (e.g., packaging, batteries and electronic equipment) – the divergences in terms of obligations, registration and reporting can increase threefold. Even more disturbing, if that same producer is trying to make the most of the EU Single Market and sell its products in more than one Member State – the complexity can just get out of hand. That producer would end up managing 81 different compliance processes at once if it wanted to sell its packaged laptop in 27 Member States.
In a nutshell, producers are facing structural problems. On the one hand, the lack of coherence between product streams within Member States. On the other hand, the lack of convergence on EPR systems between Member States.
EPR compliance in the EU: what is the solution?
Harmonisation of EPR compliance among product streams and across Member States must remain a long-term objective. Nevertheless, this takes time and strong political willingness – while it is an evidence that decades of calls for harmonisation have yielded limited convergence. But time is a resource that many small, European companies do not have, especially in the face of harsher competition from operators based in third countries. This should make the immediate reduction of administrative burdens and compliance costs a top priority for EU policymakers.
Digitalisation of EPR compliance is a powerful tool that has not been used enough until today. But how exactly can digitalisation deliver for easier, smoother EPR compliance? Digital tools can cope with complexity, fragmentation, discrepancies better than humans do – just think of the potential to reduce error rates and cases of “accidental” non-compliance. Digital tools have the potential to centralise information about EPR and optimise registration and reporting processes.
The case for a digital, EU-wide One-Stop Shop for EPR
To showcase how digitalisation can concretely support and drive EPR compliance, a Coalition of industry and other stakeholders, led by Ecommerce Europe, has been exploring and defining the concept of a digital, EU-wide One-Stop Shop (OSS) for EPR. What exactly is an OSS? How does it differ from the concept of an EU-wide register for EPR? What functionalities could it have, and how could it reduce the burden on companies? What would it take, in terms of policy changes, to make this happen?
Many of these questions are still being explored – but a few of them have already been answered. An OSS would consist of a two-way, digital platform that serves as an intermediary digital layer between producers, national authorities, PROs and national public registers. Producers – or entities acting on their behalf – would use the digital OSS platform to navigate EPR information, fulfil registration and reporting across product streams and across Member States. PROs, registers and authorities would also have access to the platform to monitor compliance and enforce EPR rules.
The EU EPR OSS has the potential to become a gamechanger in the EU EPR compliance landscape. It would not only offer a new way to address the problems affecting EPR, but it would also allow the EU to pursue its simplification and competitiveness goals. Finally, it would provide a golden opportunity for the European Commission to reassert its coordinating authority on EPR policy in the EU.
Join the Coalition for a digital EU EPR OSS!
The Coalition for a digital EU EPR OSS is open to all stakeholders with an interest in simplifying EPR compliance. Are you motivated to help shape the platform’s design and technical specifications, so that it meets the needs of producers, PROs, and other key actors across the EU? Read more about the Coalition’s objectives and achievements and get in touch with us.
