What is Extended Producer Responsibility (EPR)?

Extended Producer Responsibility (EPR) moves the cost of dealing with waste from taxpayers to the companies that make and sell products. If you place a product on a market, you help pay for collecting, sorting and recycling it when it is thrown away.

EPR is not one EU law. The general rules are in Articles 8 and 8a of the Waste Framework Directive, and product-specific laws make EPR mandatory for certain product groups. Each EU country then runs its own schemes, with its own registers, fees and reporting. A brand selling in ten countries usually has ten sets of EPR obligations per product group.

How EPR works

1. Register as a producer in each country where you first make the product available, often per product category.
2. Join a producer responsibility organisation (PRO) or comply individually. Most companies join a PRO that runs collection and recycling for many brands.
3. Report what you place on the market, usually by weight or units and by material, every year or more often.
4. Pay fees that cover collection, sorting, recycling, information campaigns and reporting.
5. Show your registration number where required, for example to online marketplaces.

The Waste Framework Directive requires fees to be modulated: products that are more durable, repairable, reusable or recyclable, or that contain fewer hazardous substances, should pay less. This is where EPR starts to reward product design and not only volume.

Which products have EPR in the EU

Required by EU law today:

• Packaging, now under the Packaging and Packaging Waste Regulation (EU) 2025/40, which applies from 12 August 2026 and links fee modulation to recyclability and recycled content.
• Electrical and electronic equipment, under the WEEE Directive 2012/19/EU. These products also have to meet RoHS.
• Batteries, under the EU Battery Regulation, for all battery categories.

Textiles and footwear: Directive (EU) 2025/1892 entered into force on 16 October 2025. It requires every EU country to set up EPR for clothing, accessories, household textiles such as bed linen and curtains, and footwear by 17 April 2028. Countries may add mattresses. Producers outside a country that sell there directly may need an authorized representative, and online platforms must check a seller's EPR registration before allowing it to sell these products.

National schemes: countries can go further. France runs EPR schemes (called REP) for many more categories, including furniture, toys, sports and leisure goods and DIY tools, and has had textile EPR since 2007. See the AGEC law.

What it means for your products

• You need accurate product data: weights, materials, components and packaging, per product and per country.
• Design choices affect fees. As modulation criteria become linked to ESPR ecodesign requirements, the same data you collect for a Digital Product Passport will drive your EPR costs.
• The producer is often you, even if you do not manufacture. Brands that sell under their own name, importers and foreign sellers shipping direct to consumers are all producers for EPR purposes. Check which economic operator role you hold in each market.

How to prepare

• List every country and product category you sell in, and check which EPR schemes apply.
• Register with the right PROs before you start selling, and keep registration numbers ready for marketplaces.
• Build a product data set with materials, weights and packaging that can feed EPR reports and passports at once.
• For textiles and footwear, plan for national schemes to appear in each EU country before April 2028.
• Track eco-modulation criteria, as better-designed products can lower your fees.