Real EPR Questions Top Brands Are Asking in Europe
Attendees of RLG’s recent webinar, From Uncertainty to Compliance: How to Close Your EPR Gaps, the second installment of our EPR Compass series, had some excellent questions about environmental compliance.
While we ran out of time to answer every question during the webinar, we remain committed to supporting producers throughout the process of preparing their data for reporting under EPR laws. So, we have chosen to publish answers to all of the questions—we hope you find them helpful.
Please be advised that this post is for information purposes only; for insights into your company’s circumstances, consult a lawyer or advisor.
Are you curious about your company’s current standing on EPR? Take our quick self-check quiz to assess your compliance status in under a minute.
Question 1: Could one take a position as a company, ‘Our customers need to cover the Extended Producer Responsibility (EPR) responsibilities’?
The regulations generally don’t allow for this. EPR obligations are typically assigned to the ‘producer,’ which is defined in various ways across different countries. In most cases, the producer is the entity that places the product on the market, this could be the manufacturer, importer, or distributor, depending on the specific regulations. Furthermore, the specific sales channels you utilize play a significant role in determining your responsibilities. For example: If you sell directly to consumers, you’re more likely to be considered the producer. If you sell through distributors, the responsibility might fall on you or the distributor, depending on the agreement and the applicable regulations. Online sales also have specific definitions and responsibilities. It’s crucial to thoroughly examine the specific EPR regulations in each country where you operate and to understand how your sales channels impact your obligations.
Question 2: How long does it typically take to go from identifying our EPR obligations to achieving full regulatory compliance?
It really depends on the complexity of your product portfolio and the number of countries you operate in. We can generally break the process down into two key parts: understanding the regulations and setting up the reporting systems, and then the ongoing compliance obligations.
The initial phase, which involves identifying your specific obligations across all relevant jurisdictions and establishing the necessary compliance registrations and reporting channels, can typically take up to a few months to half a year. A major factor here is data availability. Gathering accurate data on your products, packaging, and sales volumes across different markets can be time-consuming.
Once the initial setup is complete, EPR compliance becomes an ongoing process. This involves regularly submitting reports to compliance schemes, staying up-to-date with changes in regulations, managing contracts and payments with compliance schemes, and ensuring continuous data accuracy. So, while the initial phase might take several months, EPR compliance is not a one-time project. It requires continuous effort and adaptation.
Question 3: Does Extended Producer Responsibility (EPR) vary by country? And how do you help companies speed up the process of getting compliant?
Absolutely, the EPR compliance process varies significantly from country to country. Each nation has its own specific regulations, definitions of ‘producer,’ and reporting requirements. We help companies speed up the process in several ways. Our team is comprised of experts who are familiar with the EPR regulations in various countries. We stay up-to-date with the latest changes and can provide accurate and timely advice. We also have direct communication with approved schemes. We have established relationships and direct communication channels with approved producer responsibility organizations (PROs) across Europe. This allows us to streamline the registration and reporting processes, avoiding unnecessary delays.
Question 4: Can you give us a quick update on the progress of PPWR? What is the next important deadline for businesses?
The Packaging and Packaging Waste Regulation (PPWR) entered into force on 11 February 2025. The general date of application for the PPWR is 18 months after its entry into force, meaning it will be broadly applicable in mid-2026. Key objectives of the PPWR include minimizing packaging waste and promoting reuse/refill, making all EU packaging recyclable by 2030, increasing recycled plastic use, and reducing virgin material use to achieve climate neutrality by 2050. Therefore, companies should immediately begin assessing their packaging practices against the PPWR’s requirements. The deadline for all packaging to be recyclable is 2030.
Question 5: What are the main differences in terms of Extended Producer Responsibility (EPR) for B2B and B2C environments?
The differences in EPR obligations between B2B and B2C can be approached from two angles, and it’s essential to understand which aspect you’re referring to. Are we looking at the type of waste generated (for example, industrial equipment vs. consumer equipment), or are we considering the sales channels (direct business-to-business transactions vs. retail or online sales to consumers)?
Waste Type: B2B often involves specialized waste streams requiring specific handling, while B2C typically deals with household waste.
Sales Channels: B2B sales might have clearer contractual responsibilities, while B2C can be more complex due to diverse distribution.
To give you a more precise answer, we need to clarify whether you’re asking about the waste type or the sales channels.
Question 6: For skin care products packaging compliance, what is the first deadline I should consider? Is it PPWR?
While there aren’t specific, standalone packaging regulations exclusively for skin care products currently, businesses must still adhere to general packaging rules and Extended Producer Responsibility (EPR) regulations in each country where they operate. This means that even though there isn’t a regulation solely for skincare packaging, you’re still responsible for ensuring that your packaging complies with the broader packaging laws of that region.
Additionally, upcoming regulations, such as the EU’s Packaging and Packaging Waste Regulation (PPWR), may introduce new requirements that specifically impact skincare packaging. We are currently analyzing the PPWR to identify any potential future obligations for skincare products.
It’s important to stay informed about these evolving regulations, as they may include new labeling, material restrictions, or other requirements that could affect your skincare product packaging.
Question 7: Does RLG provide support for US Extended Producer Responsibility (EPR) laws?
es, RLG supports businesses in navigating Extended Producer Responsibility (EPR) laws in the United States. Unlike the EU, where EPR is regulated at the national level, US EPR laws vary by state, making compliance complex. RLG helps companies meet these state-specific obligations through. As EPR regulations in the US continue to expand—especially for packaging, which is now regulated in states like Maine, Oregon, Colorado, and California—RLG helps businesses adapt to these changes and streamline compliance.
Question 8: Do you have readymade templates available for EPR data and EPR reporting?
es, RLG provides standardized data reporting templates to help businesses efficiently submit compliance data. These templates are designed to align with various EPR reporting requirements across multiple countries and jurisdictions. An example of what the templates cover:
- Packaging: Material composition, weight, recyclability, and distribution data for reporting under packaging EPR laws.
- Electronics & Batteries: Product categories, volumes sold, and take-back data for WEEE and battery compliance.
If you need a specific template or guidance on how to use them, RLG can provide further assistance based on your compliance obligations.
Question 9: How will the new battery categories, as defined in the recent EU Battery Regulation, impact the market for the e‑bikes and e‑scooters?
The new EU Battery Regulation introduces a separate category for light transport (LV) batteries, which will significantly affect the e‑bike and e‑scooter markets. This means there will be increased focus on the environmental impact of LV batteries, leading to stricter oversight and enforcement to ensure proper production as well as disposal. The regulation also aims to push for standardized safety and performance requirements. Additionally, specific collection targets for LV batteries have been set—I am not sure about the number right now but it is for sure above 60% by 2030—requiring stronger collection and recycling systems to meet these goals.
Question 10: In general, when selling packaged goods from an EU country to another EU country, is the importer responsible for Extended Producer Responsibility (EPR) compliance?
Generally, within the EU, EPR responsibility falls on the ‘producer.’ However, for packaged goods moving between EU countries, determining the producer can be complex. While manufacturers and importers are often considered producers, the specific interpretation depends on national legislation and the details of how the packaging is placed on the market in each country. Therefore, whether it’s the importer who is responsible, depends on the specifics of the national legislation. A thorough assessment of your specific situation and the relevant regulations is crucial to accurately determine EPR responsibilities.
Did We Answer Your Questions About Extended Producer Responsibility (EPR) Laws in Europe?
We hope this publication has been helpful. If you have a question about EPR laws in Europe—or anywhere worldwide—please do not hesitate to contact us. We would be happy to connect you with one of our EPR experts.
Disclaimer: This article is for informational purposes only and should not be regarded as legal counsel. Information is valid as of the time of publication and is subject to change. Always refer to primary sources for the most up-to-date information.
