Startup landscape: Extended Producer Responsibility (EPR) — the companies to watch and why

Extended Producer Responsibility regulations now cover more than 400 product categories across 73 countries, and the global EPR compliance market reached an estimated $38 billion in 2025, growing at 14% annually as governments expand mandatory take-back, recycling, and reporting obligations to packaging, electronics, textiles, and batteries (OECD, 2025). This rapid regulatory expansion has created a wave of startup activity across compliance software, collection infrastructure, material recovery, and data analytics, with venture capital investment in EPR-adjacent companies exceeding $2.1 billion between 2022 and 2025. This article maps the startup landscape, identifies the companies to watch, and explains what differentiates the leaders from the rest.

Why It Matters

EPR is shifting from a niche waste policy mechanism to one of the primary regulatory levers governments use to drive circular economy outcomes. The EU's Packaging and Packaging Waste Regulation (PPWR), finalized in 2024, mandates that all packaging sold in the EU meets minimum recycled content targets (30% for plastic packaging by 2030) and requires producers to fund collection and recycling infrastructure through EPR fee payments calibrated to packaging recyclability. France's AGEC law expanded EPR to 13 new product categories between 2022 and 2025, including construction materials, toys, and sporting goods. In the United States, five states enacted EPR for packaging between 2021 and 2025, with Oregon, Colorado, California, Maine, and Minnesota each implementing distinct compliance frameworks.

For product and design teams, EPR is no longer a downstream compliance issue handled exclusively by sustainability departments. EPR fee structures increasingly use eco-modulation, where producers pay lower fees for products designed for recyclability and higher fees for products that are difficult to recycle. France's Citeo scheme applies fee bonuses of up to 20% for packaging that meets specific design-for-recycling criteria and penalties of up to 100% for packaging that disrupts recycling streams (Citeo, 2025). This direct financial link between product design decisions and EPR costs means design teams need real-time visibility into how material choices, packaging formats, and labeling affect EPR obligations across multiple jurisdictions.

The compliance challenge is compounded by regulatory fragmentation. A consumer goods company selling across 15 European markets may face 15 distinct EPR reporting requirements, each with different fee calculation methodologies, packaging category definitions, weight thresholds, and reporting deadlines. The startups that are gaining traction are those solving this fragmentation through software automation, cross-jurisdictional data aggregation, and integrated compliance workflows that reduce the operational burden on producers.

Key Concepts

Eco-modulation is the practice of adjusting EPR fees based on a product's environmental performance characteristics, particularly its recyclability, recycled content, durability, and repairability. Well-designed eco-modulation creates financial incentives for product design improvements: producers that use mono-material packaging or incorporate high percentages of post-consumer recycled content pay lower fees than those using multi-material laminates or virgin plastics.

Producer Responsibility Organizations (PROs) are the entities, typically industry-funded nonprofits or government-mandated bodies, that collect EPR fees from producers and use them to fund collection, sorting, and recycling infrastructure. In many jurisdictions, PROs hold monopoly or oligopoly positions (e.g., Der Grune Punkt in Germany, Fost Plus in Belgium). Startups are increasingly competing with or complementing PROs by offering digital-first compliance services.

Material recovery facility (MRF) optimization refers to technologies and data systems that improve sorting accuracy, throughput, and material quality at the facilities where collected packaging and products are separated by material type for recycling. EPR systems depend on MRF performance to meet recycled content and recovery rate targets.

Digital product passports (DPPs) are standardized digital records that accompany products through their lifecycle, containing information about materials, manufacturing, and end-of-life handling. The EU's Ecodesign for Sustainable Products Regulation mandates DPPs for batteries (from 2027), textiles, and electronics, creating a direct data infrastructure requirement for EPR compliance.

What's Working

Circulytics by Lizee: Reuse Logistics at Scale

Lizee, founded in Paris in 2020, built a software and logistics platform that enables brands to launch and scale product reuse programs, which directly reduce EPR fee obligations by extending product lifecycles. The company's platform manages reverse logistics, refurbishment workflows, inventory tracking, and consumer-facing rental and resale interfaces. By 2025, Lizee had onboarded more than 40 brand clients across fashion, childrenswear, and sporting goods, processing over 500,000 reuse transactions annually (Lizee, 2025).

Lizee's value proposition to product teams is concrete: by routing products through reuse cycles before end-of-life, brands reduce the volume of waste attributed to them under EPR calculations. For a mid-size fashion brand generating 200 tonnes of post-consumer textile waste annually, Lizee's modeling shows that achieving a 15% reuse rate can reduce EPR fee exposure by 10 to 18% depending on the jurisdiction, while generating incremental revenue from resale and rental channels. The company raised EUR 10 million in Series A funding in 2024, led by Ring Capital, and is expanding into Germany and Spain.

Grover: Electronics Reuse Reducing EPR-Liable Waste Volumes

Grover, the Berlin-based electronics subscription platform founded in 2015, has scaled to more than 500,000 active subscriptions across Germany, Austria, the Netherlands, Spain, and the United States. The company's circular model, where consumers subscribe to electronics rather than purchasing them, directly addresses EPR obligations by keeping devices in use longer and routing end-of-life units through certified refurbishment rather than waste streams. Grover reports that devices on its platform average 3.2 use cycles before retirement, compared to the industry average of 1.3 cycles for purchased electronics (Grover, 2025).

For electronics producers, Grover's model reduces the volume of e-waste generated per unit sold, which lowers EPR fee calculations in jurisdictions that assess fees based on units placed on market minus units recovered for reuse. The company has raised more than $1 billion in equity and debt financing, with its most recent funding round of $110 million in 2023. Grover's technology stack includes device condition assessment algorithms, predictive maintenance scheduling, and automated cosmetic grading, which together enable refurbishment at scale with rejection rates below 4%.

Recykal: Digital EPR Compliance Infrastructure for India

Recykal, founded in Hyderabad in 2015, built a digital marketplace and compliance platform that connects waste generators, recyclers, and producers across India's rapidly expanding EPR framework. India's Central Pollution Control Board mandated EPR for plastic packaging in 2022 and extended it to e-waste, batteries, and tires, creating compliance obligations for more than 50,000 producers. Recykal's platform processed more than 400,000 tonnes of waste through verified recycling channels in 2024 and onboarded over 3,000 brands, recyclers, and waste processors onto its marketplace (Recykal, 2025).

The platform solves a critical pain point in emerging market EPR implementation: the gap between regulatory mandates and on-ground recycling infrastructure. Recykal provides producers with auditable certificates of recycling, GPS-tracked collection data, and automated compliance reporting that meets state and national regulatory requirements. The company raised $22 million in Series B funding in 2024 and is expanding to cover construction and demolition waste, which India brought under EPR obligations in 2025.

What's Not Working

Regulatory fragmentation across jurisdictions continues to challenge even the best-funded compliance platforms. Despite efforts at EU-level harmonization through the PPWR, national implementations retain significant variation in fee structures, reporting formats, and product category definitions. Startups that built platforms for a single jurisdiction face expensive re-engineering when expanding to new markets, with each new country requiring 6 to 12 months of regulatory mapping and system adaptation.

PRO resistance to digital disruption slows startup adoption in markets where incumbent PROs hold strong positions. In several European countries, PROs have exclusive or semi-exclusive mandates to manage EPR systems, and they have been slow to adopt third-party compliance technologies. Startups offering producer-facing compliance tools must navigate complex relationships with PROs that may view them as competitors rather than partners. In Germany, the introduction of the Central Packaging Registry (LUCID) in 2019 created a more open compliance environment, but other markets remain structurally resistant to new entrants.

Data quality in collection and recycling chains undermines the accuracy of EPR compliance reporting. In both developed and emerging markets, the gap between reported recycling rates and actual material recovery remains significant. The European Environment Agency estimated in 2024 that reported packaging recycling rates in the EU overstated actual material recovery by 10 to 15 percentage points due to measurement inconsistencies, with some countries counting materials "sent for recycling" rather than materials "actually recycled" (EEA, 2024). Startups that rely on downstream recycler data for compliance certificates face reputational risk when verification processes are insufficient.

Limited eco-modulation sophistication reduces the design incentive signal that EPR is supposed to create. While France's Citeo system applies meaningful fee differentiation, many other EPR schemes use flat per-tonne fees with minimal or no adjustment for product design attributes. In these markets, startups building tools to optimize product design for EPR fee reduction have a weaker value proposition because the fee savings from design improvements are marginal compared to the cost of implementation.

Key Players

Established Companies

• Citeo: France's primary PRO for household packaging and paper, managing EUR 850 million in annual EPR fees and pioneering advanced eco-modulation frameworks
• Der Grune Punkt (Duales System Deutschland): Germany's largest compliance scheme for packaging EPR, serving more than 100,000 producers
• Veolia: global waste management and recycling company operating material recovery infrastructure that underpins EPR collection and recycling targets across Europe

Startups

• Lizee: Paris-based reuse logistics platform enabling brands to launch product reuse programs that reduce EPR-liable waste volumes
• Grover: Berlin-based electronics subscription platform extending device lifecycles through rental and certified refurbishment
• Recykal: Hyderabad-based digital marketplace connecting producers with verified recyclers for EPR compliance across India
• Valpak: UK compliance solutions provider offering EPR data management, packaging assessment, and regulatory reporting for producers
• Scrapp: Copenhagen-based startup using AI-powered packaging scanning to automate EPR fee classification and design-for-recycling assessment
• Bower: Swedish consumer rewards platform incentivizing packaging returns through mobile scanning and deposit-return integration

Investors and Funders

• Ring Capital: Paris-based growth equity firm backing circular economy and climate tech startups across Europe, led Lizee's Series A
• Circulate Capital: impact investment firm focused on circular economy infrastructure in South and Southeast Asia, active in EPR-adjacent waste management
• European Circular Bioeconomy Fund (ECBF): EU-backed fund investing in companies developing circular materials, recycling technologies, and EPR compliance solutions

Action Checklist

• Map current EPR obligations across all markets where products are sold, documenting fee structures, eco-modulation criteria, and reporting deadlines for each jurisdiction
• Evaluate compliance automation platforms that aggregate multi-jurisdiction EPR reporting into a single workflow, comparing coverage breadth, data integration capabilities, and regulatory update frequency
• Conduct a packaging design audit against eco-modulation criteria in France, Germany, and Italy to quantify potential fee reductions from material substitution or format changes
• Assess reuse and refurbishment models for high-volume product lines, calculating the EPR fee reduction potential alongside incremental revenue from resale or rental channels
• Establish verification protocols for recycling certificates, requiring GPS-tracked collection data and material-level recovery documentation rather than accepting aggregated tonnage reports
• Engage with emerging DPP requirements by selecting a data architecture that can accommodate battery, textile, and electronics passport mandates as they take effect between 2027 and 2030
• Build cross-functional EPR working groups that include product design, packaging engineering, procurement, and regulatory affairs to ensure design decisions incorporate EPR cost implications from the concept stage

FAQ

Q: How do eco-modulated EPR fees affect packaging design decisions? A: In jurisdictions with advanced eco-modulation, such as France and Italy, packaging designers can reduce EPR fees by 10 to 25% by switching from multi-material laminates to mono-material structures, eliminating problematic adhesives or inks, and meeting minimum recycled content thresholds. For a company paying EUR 2 million annually in packaging EPR fees, these design changes can yield EUR 200,000 to 500,000 in annual savings while improving actual recyclability. Product teams should request detailed eco-modulation fee schedules from their PRO or compliance provider and model the cost impact of specific design changes before committing to packaging specifications.

Q: Which EPR compliance startups are best suited for companies operating across multiple European markets? A: Companies operating in five or more EU markets should prioritize platforms that offer pre-built regulatory mappings for at least the major markets (France, Germany, Italy, Spain, Netherlands, and the Nordics), automated data collection integrations with ERP and packaging management systems, and proactive regulatory update services that flag changes to fee structures and reporting requirements. Scrapp and Valpak currently offer the broadest European coverage among startup-stage providers, while larger consultancies like Lorax Compliance and EY provide multi-jurisdiction services at higher price points.

Q: What is the timeline for EPR expansion to new product categories? A: Between 2025 and 2030, EPR is expected to expand to textiles (EU-wide by 2028), construction materials (France active, EU proposal expected by 2027), furniture (France active, Netherlands piloting), and commercial fishing gear (EU PPWR mandates). India is extending EPR to construction and demolition waste and is exploring coverage for furniture and mattresses. Companies manufacturing in these categories should begin mapping their waste profiles, identifying potential PRO partners, and evaluating compliance platform options 18 to 24 months before regulatory deadlines.

Q: How should companies evaluate the credibility of recycling certificates provided through EPR compliance platforms? A: Request documentation that includes GPS-tracked collection logs showing pickup location and timestamp, material composition analysis at intake (near-infrared or manual sampling), processing records from the recycling facility showing input tonnage and recovered material output, and independent third-party audit reports. Platforms that provide only aggregated tonnage certificates without facility-level documentation should be treated with caution. The ISCC PLUS and EuCertPlast certification frameworks provide recognized verification standards for recycled content claims.

Sources

• OECD. (2025). Extended Producer Responsibility: Updated Guidance for Efficient Waste Management. Paris: OECD Publishing.
• Citeo. (2025). Eco-Modulation Fee Schedule 2025: Packaging Design Criteria and Fee Adjustments. Paris: Citeo.
• European Environment Agency. (2024). Packaging Waste Statistics: Measurement Methodologies and Data Quality Assessment. Copenhagen: EEA.
• Lizee. (2025). Reuse Platform Impact Report 2024: Brand Adoption, Transaction Volumes, and Circular Outcomes. Paris: Lizee SAS.
• Grover. (2025). Circular Electronics Report 2025: Device Lifecycle Extension and Environmental Impact. Berlin: Grover Group GmbH.
• Recykal. (2025). EPR Compliance and Digital Waste Management: India Market Report 2024-2025. Hyderabad: Recykal Foundation.
• Textile Exchange. (2025). Preferred Fiber and Materials Market Report 2025. Lamesa, TX: Textile Exchange.