Interview: Practitioners on Extended Producer Responsibility (EPR) — From Pilots to Scale

Extended Producer Responsibility is reshaping how cities, utilities, and producers manage packaging waste. With the UK's Producer Responsibility Obligations regulations taking effect in January 2025 and the EU's Packaging and Packaging Waste Regulation (PPWR) applying from August 2026, organizations across Europe and North America are transitioning from pilot programs to full-scale implementation. We spoke with practitioners who have navigated this journey to understand what works, what doesn't, and how to scale successfully.

The Pilot Results: What the Numbers Tell Us

Q: What recycling improvements have you observed in jurisdictions with mature EPR programs compared to traditional municipal systems?

A: The data is compelling. In our analysis of seven international EPR programs, we found that jurisdictions like Belgium achieve 95% recycling rates, while British Columbia, Spain, South Korea, and the Netherlands consistently exceed 75%. Compare that to the U.S. baseline where only 43% of households participate in recycling programs.

British Columbia's Recycle BC program stands out. When China's National Sword policy disrupted global recycling markets in 2018, U.S. recycling costs surged 200%. British Columbia? Their costs rose only 26% because they had invested in local processing infrastructure. Since 2014, the program has saved municipalities over $400 million in waste management costs while maintaining a 78% recovery rate for plastic packaging.

The pilot cities in the U.S. are showing similar promise. Denver's education campaign achieved a 27% increase in capture rates and 57% reduction in contamination—all at a cost of just $1.50 to $2 per household.

The Operational Playbook: Building Producer Responsibility Organizations

Q: How do Producer Responsibility Organizations actually work in practice, and what model is proving most effective?

A: Two primary models have emerged. The producer-run PRO model, used in Oregon, Colorado, and California, puts industry in the driver's seat. The Circular Action Alliance, founded by companies like Amazon, Coca-Cola, and Mars, now operates as the designated PRO across seven U.S. states. Producers register, submit annual packaging data, and pay fees based on material type and recyclability.

The alternative is Maine's municipal cost-reimbursement model, where producers reimburse municipalities directly for waste management costs rather than managing the infrastructure themselves.

In Europe, it's more fragmented—each EU member state has its own approved PROs. France has Léko and CITEO, Belgium has Fost Plus, and producers must register in each country where they sell. The UK's PackUK system, effective January 2025, consolidates administration across all four nations.

The key insight? Successful PROs focus on three things: stable producer funding, investment in local recycling infrastructure, and uniform accepted materials lists that reduce consumer confusion.

Scaling Challenges: What Keeps Practitioners Up at Night

Q: What are the biggest operational challenges when scaling from pilot to full implementation?

A: Data infrastructure is the single biggest hurdle. EPR requires SKU-level tracking of packaging types, materials, weights, and recyclability. Many companies simply don't have this information organized. Under the UK's pEPR regulations, large producers must report bi-annually and complete Recyclability Assessment Methodology assessments. The EU's PPWR will require digital labeling with QR codes by 2027.

Fee structures create real financial pressure. The UK's Year 1 fees start at £423 per tonne for plastic and £192 per tonne for glass. From 2026-27, modulated fees based on recyclability ratings will mean red-rated packaging costs significantly more than green-rated alternatives. The total cost shift from local authorities to producers is approximately £1.2 billion annually.

Oregon began collecting EPR fees in July 2025 at $0.17 to $0.23 per pound of covered material. Non-compliance penalties reach $25,000 per day. California's CalRecycle will collect $500 million annually from producers between 2027 and 2037.

The fragmentation across jurisdictions is exhausting. U.S. companies now face seven different state programs with varying timelines, data formats, and fee structures. Five more states have active bills under consideration.

Lessons Learned: Design for Recyclability from Day One

Q: What strategic lessons should procurement teams take from early EPR implementations?

A: The companies treating EPR strategically—not just as a compliance burden—are capturing 6% to 25% revenue uplifts through expanded market share, pricing premiums, and new product offerings. Research shows 90% of consumers prefer brands with sustainable packaging, and sustainability-marketed products command an average 26.6% price premium.

Eco-modulation is the key lever. Oregon's program charges lower fees for easy-to-recycle packaging like PET. Converting to recyclable materials, increasing post-consumer recycled content, and conducting life cycle assessments all reduce fees while improving brand perception.

Germany's experience is instructive. Their green dot system achieved a 3% annual reduction in packaging between 1991 and 1997, compared to a 2-4% annual increase before implementation. Japan achieved 93% recycling rates for PET bottles by 2021. These results came from decades of producer investment in design-for-recycling.

The EU's PPWR raises the bar further. By 2030, all packaging must be recyclable with minimum 30-65% recycled content for plastics. By 2035, recyclability must be demonstrated at scale.

The Path Forward: Integration with Broader Sustainability Goals

Q: How does EPR connect to broader corporate sustainability and reporting requirements?

A: EPR is becoming inseparable from Scope 3 emissions reporting and CSRD compliance. When you redesign packaging for recyclability, you simultaneously reduce upstream carbon intensity. The EU estimates EPR has contributed to a 50% reduction in packaging waste going to landfills over the past 20 years and driven a 27% increase in patents related to plastic recycling technologies since 2010.

The infrastructure investment is creating jobs—over 300,000 in the EU recycling sector alone. Each implementing U.S. state projects $13 to $91 million in recovered material value and thousands of new positions.

For procurement teams, the message is clear: packaging decisions made today determine compliance costs for the next decade. Suppliers who can demonstrate recyclability, recycled content, and robust data tracking are becoming essential partners.

Key Takeaways

1. EPR programs consistently achieve 75-95% recycling rates compared to 43% baseline participation in traditional municipal systems.

2. British Columbia's model demonstrates cost resilience—only 26% cost increase during market disruptions versus 200% in non-EPR jurisdictions.

3. Data infrastructure is the primary scaling challenge—SKU-level packaging tracking is now essential for compliance.

4. UK pEPR fees start at £423/tonne for plastic with modulated pricing based on recyclability from 2026-27.

5. Strategic companies capture 6-25% revenue uplifts by treating EPR as a market opportunity rather than compliance burden.

6. EU PPWR mandates 30-65% recycled content by 2030—early movers will secure supply chains while competitors scramble.

Action Checklist

• Audit packaging data by SKU for material types, weights, and recyclability ratings before April 2025 reporting deadlines
• Register with appropriate PROs (PackUK for UK, Circular Action Alliance for U.S. states, national PROs for EU markets)
• Budget for EPR fees based on current material mix—UK estimates £1.2 billion total annual cost shift to producers
• Conduct Recyclability Assessment Methodology evaluations to identify red-rated packaging for redesign priority
• Engage suppliers on recycled content targets—secure 30-65% PCR supply chains ahead of 2030 EU mandates
• Implement digital labeling systems with QR codes for material composition and recycling instructions by 2027
• Track state and regional legislation as five additional U.S. states and ongoing EU implementation expand requirements

Sources

• UK Government, "Extended Producer Responsibility for Packaging," GOV.UK, January 2025. https://www.gov.uk/guidance/extended-producer-responsibility-for-packaging
• European Commission, "Regulation (EU) 2025/40 on Packaging and Packaging Waste," EUR-Lex, January 2025. https://eur-lex.europa.eu/eli/reg/2025/40/oj
• The Recycling Partnership, "Increasing Recycling Rates with EPR Policy," 2024. https://recyclingpartnership.org/eprreport/
• Product Stewardship Institute, "Extended Producer Responsibility for Packaging and Paper Products: Policies, Practices, and Performance," 2024. https://productstewardship.us/
• Circular Action Alliance, "About CAA," 2025. https://circularactionalliance.org/about
• Recycle BC, "2024 Annual Report," British Columbia, Canada.
• Oregon Department of Environmental Quality, "Packaging EPR Implementation," 2025.
• PwC, "How do state extended producer responsibility laws affect my company?" 2025. https://www.pwc.com/us/en/services/esg/library/extended-producer-responsibility-laws.html