Failure to comply with the rules of Extended Producer Responsibility (EPR) carries a number of sanctions, ranging from a restriction or complete ban on the sale of a product, to loss of brand reputation, to monetary fines or confiscation of goods. More and more countries are adopting EPR as a mandatory environmental policy, so its tenets are strictly enforced. Manufacturers that fail to comply with its provisions or use inappropriate waste management practices face numerous consequences. The severity of possible restrictions depends on both the scale of the violation and the size of the company, while their effects have a…
What exactly is EPR?
Extended Producer Responsibility (EPR) is a type of environmental policy that was first implemented in Sweden and has subsequently gained popularity in many countries around the world. The policy is based on the “polluter pays” principle, thus regulating the producer’s responsibility for the products they put on the market. Its application directly contributes to the development of a circular economy.
The main goal of EPR is proper waste management and sustainable consumption of raw materials.
According to the policy, manufacturers are responsible for the entire life cycle of products, from the moment they are manufactured to the end of their useful life. Accordingly, regulations govern the management of generated waste through payment of fees for collection, recycling, reuse and disposal.
Who is affected by the EPR regulations?
In short, the provisions of Extended Producer Responsibility apply to any person who takes part in a product’s introduction to the market. In other words, any legal or natural person whose business activity consists of developing, manufacturing, processing, selling or importing products, regardless of how they are placed on the domestic market.
Companies that sell their products directly to end consumers (B2C) are subject to different regulations than those that trade with retailers or distributors (B2B). Moreover, the requirements applied to domestic sellers differ from those applied to international sellers. Therefore, it is important to consider the type of business you are doing in order to correctly determine your obligations.
Who should apply for an EPR registration number?
- Individuals and companies that manufacture products subject to EPR
- Vendors of products subject to EPR
What products are subject to EPR?
In order to reduce waste and contribute to the development of a circular economy, the particulars of EPR are regularly updated. According to experts’ predictions, more and more products will be strictly regulated in the coming years.
Products covered by EPR:
- Packaging
- Batteries
- Electrical and electronic equipment
- Used industrial oils
- Tires
- Vehicles
- Furniture
What is a Producer Responsibility Organization (PRO)?
A Producer Responsibility Organization (PRO) (PRO) is an entity established under the Extended Producer Responsibility (EPR) system. Its task is to relieve producers of their responsibilities for managing waste resulting from their operations, in particular collection, recovery and recycling.
Key features and role of PRO:
- Assumption of producer obligations: PRO acts on behalf of producers, assuming their waste management obligations. Producers pay fees to the PRO, which funds recycling and recovery activities.
- Waste management: PRO is responsible for organizing the collection, transport, recycling, and reuse of waste generated from products placed on the market.
- Supporting a circular economy: Through waste reuse and recycling activities, PRO contributes to waste minimization and supports sustainable development.
- Regulations: PRO’s operations are strictly regulated in each country, often stemming from EU directives such as Directive 2008/98/EC on waste. These organizations are often subject to supervision to ensure compliance with regulations and the achievement of specific recycling targets.
- Application in various industries: PROs operate in many sectors, such as packaging, electronics, vehicles, batteries, and textiles. Each industry may have specific waste management requirements.
How to contact us?
Customers can contact our sustainability experts directly. At an arranged meeting, we determine how we can best meet your EPR needs. Although we operate mainly in Poland, we have many years of experience working with clients from all over Europe. Don’t hesitate to contact us if you think you could benefit from our expertise!
Do you have any questions?
Responsibilities
Extended Producer Responsibility (EPR) regulations can vary from country to country, so it is important to verify exactly what obligations apply to the specific category of products a company markets. Despite the many differences, a common feature of the vast majority of cases is the presence of declaratory and financial obligations.
The main obligations of producers in Poland under the EPR:
- Financing of waste management – manufacturers are required to cover the costs of collecting, transporting, recovering and recycling waste generated from their products. These costs include, among others:
- Selective waste collection,
- Environmental education,
- Reporting on waste management activities.
- Achieving recycling levels – manufacturers must meet certain recycling and recovery quotas, which are set by national and EU regulations. For example, in the case of packaging, a certain percentage of materials such as plastic, glass and paper are required to be recycled.
- Cooperation with producer responsibility organizations (PROs) – producers can delegate their waste management responsibilities to PRO organizations, which manage collection and recycling processes on their behalf. The producer pays an appropriate fee for this.
- Reporting – manufacturers are required to submit detailed reports on:
- The amount and type of products marketed,
- recycling and recovery activities undertaken,
- Implementation of obligations related to environmental education.
- Eco-design of products – EPR encourages manufacturers to design products in ways that minimize their environmental impact, such as by:
- Limiting the amount of materials used,
- Use of recyclable raw materials,
- Facilitating product disassembly and repair.
- Funding environmental education – manufacturers are required to conduct or finance educational activities that raise public awareness about separate collection, recycling and waste reduction.
- Product labeling obligation – products placed on the market must be labeled in a way that facilitates their subsequent segregation and recycling. This applies especially to packaging.
Example: Obligations for the packaging industry in Poland
Manufacturers marketing packaged products must:
- report the amount of packaging put on the market,
- achieve certain recycling levels (e.g., for plastic or glass),
- pay fees to the waste management system, including to PRO organizations,
- ensure that their products are labeled in accordance with regulations to facilitate selective collection by consumers.
Learn more about extended producer responsibility.
What do we offer?
We work with companies, manufacturers and individuals marketing electronic and electrical equipment, batteries and packaging, offering comprehensive support, including:
- Initial consultation to determine customer needs
- Individual case analysis
- Regulatory compliance analysis
- Calculation of estimated EPR charges
- Registration in the register of producers
- Support for appointment of attorneys
- Establish contact with Producer Responsibility Organizations
- Benchmarking and advising on EPR best practices
- Regular mapping and monitoring of legislative changes
- Advice on labeling responsibilities
