Case study: Extended Producer Responsibility (EPR) -- a city or utility pilot and the results so far

Extended Producer Responsibility (EPR) is no longer an abstract policy idea -- it is a core mechanism of the circular economy.
By shifting the cost and responsibility for end‑of‑life management onto producers, EPR aims to make disposal and recycling part of product design rather than a public burden.
This case study investigates how a city‑scale or utility‑scale pilot can turn EPR principles into reality, separating the myths from the realities and reviewing the latest results from early adopters.

Why It Matters

Municipal waste streams are overflowing, and packaging makes up a significant fraction of the volume.
The Organisation for Economic Co‑operation and Development (OECD) notes that EPR is a policy approach that makes producers responsible for their products at the post‑consumer stage.
EPR schemes have been widely adopted across the OECD and beyond and are most commonly used for electronics, packaging, vehicles and tyres.
By financing collection, recycling and safe disposal through producer fees, EPR can relieve strained municipal budgets and encourage producers to design for durability and recyclability.
Evidence from the Product Stewardship Institute shows that Connecticut’s four EPR laws diverted 26 million pounds of material, saved municipalities US$2.6 million a year, created over 100 local jobs and reduced emissions by 13 million kg CO2e.
These outcomes matter because they show that shifting responsibility upstream delivers tangible economic and climate benefits.
Countries and cities experimenting with EPR pilots seek to understand whether such benefits can scale and how to tailor programs to local conditions.
This case study focuses on a pilot in Chonburi Province, Thailand, and compares it with other examples from Brazil, the United States and China to draw lessons for engineers and policy teams.

Key Concepts

Extended Producer Responsibility (EPR). EPR is a policy framework that makes producers financially and often physically responsible for managing their products at end‑of‑life.
This responsibility includes financing collection, recycling or safe disposal and often extends to meeting design requirements (for instance, recycled content or easy disassembly).
EPR policies typically operate through Producer Responsibility Organisations (PROs).
A PRO collects fees from producers, organises collection and recycling infrastructure and reports on performance.
Mandatory schemes are established through law and include measurable targets; voluntary schemes rely on industry initiatives but may lack accountability.

Shared responsibility and reverse logistics. Brazil’s National Solid Waste Policy illustrates the principle of shared responsibility: manufacturers, importers, distributors, consumers and local authorities must implement reverse logistics for packaging waste.
In this model, waste picker cooperatives are prioritised in collection and sorting; producers invest in cooperatives in exchange for data on material recovery.
Reverse logistics is an EPR instrument that ensures that materials flow back from consumers to recyclers.

Pilot city and utility models. Pilots allow jurisdictions to test EPR concepts before scaling.
Thailand’s Action Plan on Plastic Waste Management Phase II outlines EPR implementation through pilot groups focusing on plastic products with low recycling rates.
The Thailand Institute of Packaging and Recycling Management for Sustainable Environment (TIPMSE) is implementing an EPR model across ten local administrative offices in Chonburi Province, a pilot city launched in January 2024.
The project aims to design fee structures, collect data and build local capacity ahead of nationwide rollout by 2027.
Utility‑scale pilots are similar but focus on specific waste streams (such as packaging or hazardous waste) managed by public utilities.

Quick Framework for EPR Pilots

1. Assess local waste flows. Start by auditing the types and quantities of products entering the waste stream.
   Identify materials with low recycling rates and high environmental impact.
   Thailand’s master plan targeted non‑recyclable plastic products for its pilot.
2. Design the Producer Responsibility Organisation. Define how producers will register, pay fees and participate.
   Fee modulation can reward recyclable design and penalise problematic materials.
   Transparent reporting builds trust among stakeholders.
3. Engage the informal sector. Many waste systems rely on informal collectors.
   Brazil’s reverse logistics model shows that partnerships with waste picker cooperatives can recover hundreds of thousands of tonnes of materials and provide livelihoods.
   Include these actors in pilot planning to avoid displacement.
4. Build collection and data infrastructure. Pilot cities should invest in collection, sorting and data systems.
   Oregon’s packaging EPR programme registered nearly 2,000 producers in its first month and generated millions of dollars to support education and infrastructure, illustrating the importance of early investment.
5. Evaluate and scale. Define key performance indicators (KPIs) such as diversion rates, cost savings, job creation and emissions reductions.
   Connecticut’s EPR programmes tracked tonnes diverted, municipal savings and jobs.
   Use pilot results to refine fee structures and plan national rollouts.

What’s Working and What Isn’t

What’s Working

High diversion and cost savings. Connecticut’s EPR programmes diverted 26 million pounds of material, saved municipalities US$2.6 million annually and created more than 100 jobs.
These results demonstrate that shifting end‑of‑life costs to producers frees up municipal budgets and stimulates local employment.

Rapid producer participation. Oregon’s 2024 packaging EPR programme saw nearly 2,000 producers register in the first month and generated millions in fees to support education and recycling infrastructure.
Early producer engagement is a positive sign that mandatory programmes can achieve compliance when rules and reporting mechanisms are clear.

Integration of informal workers. Brazil’s reverse logistics system mandates the prioritisation of waste pickers and obliges producers to partner with cooperatives.
This inclusion not only recovered an estimated 354,649 tonnes of packaging per year but also improved working conditions and provided access to capital for cooperatives.

Scaling through pilots. Thailand’s pilot in Chonburi demonstrates how local trials can test fee models and build administrative capacity.
The pilot covers ten local administrative offices and began in January 2024, with the goal of adapting EPR to Thailand’s context.
A clear timeline (implementation by 2027) creates accountability and focus.

What Isn’t Working

Data fragmentation and reporting gaps. The Product Stewardship Institute notes that there is no single national platform tracking EPR performance across the United States, leading to fragmented data and difficulty comparing programmes.
This fragmentation makes it hard for policymakers to evaluate success or learn from others.
Standardised reporting across states and PROs is essential.

Power imbalances and exclusion. Brazil’s reverse logistics model shows that while cooperatives receive investments, serious power inequities remain between private waste producers and cooperatives, and unaffiliated individual waste pickers may be excluded.
Ensuring fair remuneration and integrating unaffiliated collectors are ongoing challenges.

Complexity of fee modulation. Designing differentiated fee structures that incentivise recyclable design without creating excessive administrative burden is difficult.
The OECD warns that expanding EPR to new product groups and environmental impacts requires careful consideration of costs, benefits and administrative complexity.

Limited visibility in pilot cities. China’s pilot city EPR schemes in Beijing, Shanghai and Shenzhen emphasise producer accountability and recycled‑content mandates.
However, the lack of public reporting on pilot outcomes makes it hard to assess the effectiveness of these programmes.
Transparent data collection and sharing should be built into pilot design.

Examples

1. Chonburi Province, Thailand (2024 pilot). Under Thailand’s Action Plan on Plastic Waste Management Phase II, the TIPMSE selected Chonburi as a pilot city to implement an EPR model.
   The programme involves ten local administrative offices and aims to test fee structures for plastic packaging, particularly for non‑recyclable products.
   Launched in January 2024, the pilot will inform a nationwide EPR rollout by 2027.
   Early tasks include mapping waste flows, registering producers, and educating residents and businesses.

2. Brazil’s reverse logistics for packaging. Brazil’s 2010 National Solid Waste Policy mandates reverse logistics for packaging waste, assigning shared responsibility among manufacturers, distributors, consumers and local authorities.
   Waste picker cooperatives are prioritised and receive investments from producers in exchange for data on material recovery.
   The system recovers about 354,649 tonnes of packaging annually, involves approximately 5,000 organised waste pickers and partners with municipalities.
   The case illustrates how EPR can generate social benefits but also highlights power imbalances that need to be addressed.

3. Connecticut’s multi‑product EPR programmes. The Product Stewardship Institute’s study of Connecticut’s EPR laws for paint, electronics, thermostats and mattresses found that the programmes diverted 26 million pounds of material, saved US$2.6 million annually for municipalities, created more than 100 local jobs and avoided 13 million kg CO2e.
   These results show that even in relatively small states, EPR can deliver environmental, economic and social benefits.

4. Oregon’s packaging EPR plan (2024). In 2024 Oregon became the first U.S. state to approve a full packaging EPR implementation plan.
   Nearly 2,000 producers submitted reports in the first month, and millions of dollars in fees began flowing to support education and recycling infrastructure.
   This rapid producer participation demonstrates that when regulations are clear and incentives align, producers will comply and fund improvements.

5. China’s pilot city schemes. According to a review of global EPR developments, China’s Circular Economy Promotion Law enabled pilot city EPR schemes in Beijing, Shanghai and Shenzhen that emphasise producer accountability and recycled‑content mandates within a tightly controlled policy ecosystem.
   The centralised enforcement model allows rapid scaling of infrastructure and data collection but may offer limited stakeholder engagement.
   Lessons from these pilots suggest that clear mandates and oversight can accelerate implementation, although transparency remains critical.

Action Checklist

• Conduct a waste audit. Map material flows, identify high‑impact products and quantify current recycling rates.
• Engage stakeholders early. Bring together producers, local governments, waste pickers, recyclers and consumers to design the pilot.
• Design a fair fee structure. Use fee modulation to incentivise recyclable design and minimise administrative complexity.
• Establish a Producer Responsibility Organisation. Register producers, collect fees, coordinate collection and recycling and publish annual reports.
• Invest in infrastructure and data. Allocate resources to collection, sorting and data systems; encourage digital platforms to connect consumers and waste pickers.
• Pilot, evaluate and iterate. Run the pilot for at least one year, measure diversion rates, costs and social outcomes and adjust policies before scaling.
• Ensure transparency and inclusion. Require public reporting on performance, include informal workers and ensure fair remuneration.

FAQ

Q: What is the difference between EPR and traditional recycling programmes?
A: Traditional recycling programmes often depend on municipal funding and voluntary participation, leaving taxpayers to cover most costs and focusing only on collection.
EPR shifts responsibility upstream: producers pay fees to support collection, recycling and disposal, which encourages them to design products that are easier to recycle and to reduce waste.
Evidence shows that EPR can divert millions of pounds of waste and save municipalities millions of dollars.

Q: How does a Producer Responsibility Organisation (PRO) work?
A: A PRO is an entity that collects fees from producers, organises waste collection and recycling, and reports performance.
Producers register with the PRO, pay fees based on the quantity and recyclability of their products, and in return the PRO coordinates with local authorities and recyclers to ensure materials are recovered.
Effective PROs provide transparent reporting and engage stakeholders.
Oregon’s packaging PRO registered nearly 2,000 producers within one month of launching.

Q: What are the biggest challenges when implementing EPR at the city level?
A: Key challenges include building accurate data systems, designing equitable fee structures and integrating informal waste workers.
Data fragmentation can make it difficult to compare programmes and track success; creating a standard reporting framework is essential.
Additionally, pilots must address power imbalances and ensure that small cooperatives and unaffiliated waste pickers are not marginalised.
Finally, political will and public awareness are necessary to enact and enforce EPR laws.

Sources

• OECD. New Aspects of EPR: Extending producer responsibility to additional product groups and challenges throughout the product lifecycle.
• Thailand Institute of Packaging and Recycling Management for Sustainable Environment (TIPMSE). EPR legal framework and pilot programme in Chonburi Province.
• Rutkowski, J. Reverse Logistics for Packaging -- Brazil’s EPR Model.
• Product Stewardship Institute. Proven Progress: EPR Success Across the U.S..
• Awen Consulting. EPR Around the World: Regional Realities and Lessons Learned.