EC Waste Framework Directive EPR Recommendations for Guidance

12th May 2020

by Dr Chris Sherrington, Joe Papineschi, Mark Hilton, Alex Massie, Peter Jones

We were commissioned to deliver a study to support preparation of the European Commission’s guidance on the implementation of the general minimum requirements for extended producer responsibility schemes, as set out in Article 8a of the revised Waste Framework Directive.

Our study resulted in two documents:

  • The Recommendations for Guidance (downloadable below) serve to inform the Commission, based on our overall study, about specifics we identified as being necessary to address in their guidance.
  • The full report sets out the rationale for our recommendations, based on stakeholder engagement and analysis of the different approaches taken across Europe and their merits.

Areas addressed within the study include:

Waste management costs to be covered by an EPR scheme

The scope of the waste management costs that economic operators in the supply chain will need to cover through their payments into the EPR system, in respect of the products and materials for which they are responsible.

Necessary costs

An overview of current practices in applying necessary costs and how to determine the implications of any costs to be borne by producers on the viability of their services.

Existing practices  and criteria in fee modulation including packaging, EEE and batteries

The different approaches taken across the EU to fee modulation (current or planned) and consideration of the related principle, and criteria, for fee modulation for packaging, electrical and electronic equipment and batteries.

Tackling free riding

How best to create a level playing field for distributors and producers by ensuring that online (distance) sellers are also cost compliant.

For an immediate, free download of the ‘Recommendations for Guidance’ in full, please press the button below and provide a few details about yourself.