As the European Union (EU) deepens its commitment to a circular economy, Extended Producer Responsibility (EPR) is emerging as a cornerstone of waste management policy. EPR makes producers financially and operationally responsible for the end-of-life management of their products, incentivising eco-design, material efficiency, and increased recycling. However, the current patchwork of EPR schemes across waste streams (e.g. batteries, electronics, packaging, textiles, etc.) presents challenges to coherence, transparency, and efficiency. Harmonising EPR policies across waste streams is not only desirable, but also increasingly necessary.
The Case for Harmonisation
The rationale for EPR is well established. By shifting the burden of waste management from public authorities to producers, EPR can reduce environmental impacts, promote innovation in product design, and create level playing fields. Yet the way EPR is implemented varies significantly between sectors and Member States.
Some streams, like packaging, have well-established EPR systems governed by detailed EU directives. Others, such as textiles, are only now being integrated under mandatory EPR, with national systems still emerging. Batteries and Waste Electrical and Electronic Equipment (WEEE) follow their own sector-specific legislation, with separate requirements for collection, reporting, and eco-modulation.
This fragmentation leads to several issues:
- Administrative complexity for producers, especially those operating in multiple markets or selling products that span several categories (e.g., smart textiles or e-bikes).
- Inefficiencies in waste collection and treatment, with parallel systems for similar materials (e.g., plastics in packaging vs. plastics in electronics).
- Inconsistent incentives for eco-design, due to divergent fee structures, reporting formats, and modulated fee schemes.
- Missed opportunities for cross-sector innovation in reuse and recycling infrastructure.
Towards a Common Framework
To address these challenges, the European Commission is exploring options to harmonise EPR schemes across waste streams. The Circular Economy Action Plan and upcoming Circular Economy Act highlight EPR as a key policy tool. The Digital Product Passport (DPP) will also play a central role, creating the infrastructure for coherent tracking and information sharing across value chains.
But what would harmonisation look like in practice?
- Core principles and definitions: EU to define a common set of EPR principles applicable across all streams. This would include harmonised definitions of producer responsibility, recyclability, reusability, and circularity metrics.
- Standardised fee modulation criteria: Fee modulation, i.e. linking EPR contributions to the environmental performance of products, is a powerful incentive. A cross-stream framework for eco-modulation could ensure consistency and drive systemic design improvements across sectors.
- Common reporting and data requirements: Producers currently face a labyrinth of reporting obligations. Unified digital reporting formats, ideally integrated into DPP systems, could streamline compliance, and improve data quality for policy evaluation.
- Interoperable collection and treatment systems: Some materials, including plastics, textiles, metals, cut across product categories. Harmonising collection requirements and infrastructure investments can boost efficiency and enable more circular flows of materials.
- Cross-sector governance and enforcement: EPR performance varies widely across Member States, partly due to differing national implementation and enforcement. EU-wide minimum requirements and a framework for compliance checks could close the gap.
Challenges and Considerations
While harmonisation offers many benefits, it is not without challenges. Existing schemes have developed over years in response to sector-specific needs and political compromises. A “1-size-fits-all” approach may risk diluting the effectiveness of tailored systems. There must also be room for innovation and flexibility at national level.
Moreover, harmonisation efforts must consider the broader waste hierarchy. EPR is often criticised for focusing too much on recycling rather than waste prevention and reuse. A harmonised EPR framework must include strong incentives for upstream innovation, not only managing waste better, but creating less of it in the first place.
The Road Ahead
The European Commission is expected to issue further guidance on EPR harmonisation as part of its implementation of the Circular Economy Action Plan. Meanwhile, industry, Member States, and Producer Responsibility Organisations (PROs) are already working across borders and sectors to pilot joint solutions.
For example, multi-stream PROs are increasingly active in aligning operational models, integrating digital reporting systems, and supporting the development of take-back schemes that cater to multiple product types. The emergence of digital tools, such as product passports, traceability platforms, and AI-driven material recovery, can further accelerate convergence.
Conclusion
Harmonising EPR policies across waste streams is a complex but necessary step toward a truly circular European economy. As product systems become more integrated and value chains more global, fragmented national or sectoral approaches are no longer fit for purpose. A coherent, harmonised EPR framework can reduce administrative burdens, drive innovation, and ensure that Europe makes the most of its material resources, while holding producers accountable for their environmental footprint. The transition will require bold policymaking, careful coordination, and open dialogue among all stakeholders. But the prize is worth it: a system where products are designed with circularity in mind, resources are used efficiently, and waste is truly treated as a design flaw, not an inevitability.
