Extended Producer Responsibility

Debbie Hitchen

Director

United Kingdom

Liz Morris

Director

North America

Table of contents

• What is EPR
• How EPR works
• The compliance landscape
• What you need to do
• EPR Services
• Global EPR update

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What is EPR?

Extended Producer Responsibility (EPR) is an environmental policy approach that requires product manufacturers, importers and distributors to be significantly responsible for the end-of-life management of their products.

Embedded in these requirements are sustainability-oriented incentives to reduce waste from the product life cycle, promote sustainable material selection, and collect and properly dispose of post-consumer products, batteries, and packaging.

Product sustainability is an increasingly mainstream business requirement. Aside from the legislative and regulatory concerns, there is also significant business risk in ignoring the origin of components and materials, the management of toxic and harmful substances, and the sustainability impacts of consumption, disposal, and recovery.

However, as regulatory requirements vary greatly between jurisdictions and schemes, organisations often require deep subject matter expertise to help deal with the array of requirements and implementing bodies.

Anthesis helps organisations to understand and manage their EPR obligations. With over a decade’s worth of experience delivering compliance services across many different sectors, Anthesis is strategically positioned to meet the specific needs of multiple industries, including consumer goods and enterprise electronics, among others.

Common Applications & Covered Products:

• Packaging Waste: Producers fund recycling infrastructure through fees.
• Electronics (WEEE / E-Waste): Producers are responsible for collection and recycling of devices like laptops, TVs, and phones.
• Batteries, Tires, Vehicles: Producers must set up safe collection and recycling systems.
• Paint, Pharmaceuticals, Chemicals: Hazardous products fall under EPR to ensure safe disposal.
• Textiles and Mattresses: An emerging area, especially with the rise of fast fashion.

How EPR works

EPR frameworks often distribute responsibilities across the value chain while maintaining producer accountability as the central driver. This approach ensures that those who design and profit from products bear the financial and operational responsibility for their environmental impact—creating powerful market signals that reward sustainable innovation and design choices.

Product life cycle stewardship

Producers maintain responsibility for their products from design through end-of-life management. This life cycle approach ensures products and packaging are collected, recycled, and properly disposed of once consumers no longer need them.

Financial accountability

Producers fund comprehensive collection, processing, and recycling systems for their products and packaging. Fee structures often incorporate eco-modulation—rewarding sustainable design choices with reduced costs for recyclable materials and sustainable packaging solutions.

Operational excellence

Producers can either establish direct management of collection and recycling systems or collaborate through Producer Responsibility Organisations (PROs). These specialised non-profits are sometimes required by EPR legislation and orchestrate collection infrastructure, manage logistics, deliver consumer education, and ensure robust compliance reporting.

Consumer activation

Effective EPR systems engage consumers through:

• Strategic placement of collection sites for easy product returns
• Deposit-refund programmes that incentivise participation at point of purchase

Regulatory foundation

Governments establish the essential regulatory framework, define performance standards, and ensure compliance enforcement to drive system-wide transformation.

The EPR compliance landscape

EPR is traditionally implemented into national legislation with mandatory requirements. EPR for packaging, products (electronics and e-waste), and batteries are some of the most common. Additionally, emerging EPR regulations are starting to include textiles, and companies utilising textiles in their products should start preparing now to ensure they have the right data systems in place to be compliant. Since some of these requirements have been around for 20 years, there is an ongoing need for policy reform to reflect the latest product design, types, consumption trends, and resource or waste management.

Current EPR policies and similar, undergoing reform:

• Eco-design: Introducing new requirements on product performance and energy labelling, including the Ecodesign for Sustainable Products Regulation (ESPR).  Regulations are starting to require Lifecycle Analysis (LCAs) to prove the impact of eco-design choices.
• Chemicals: Updates on restricting the manufacture and sale of PFAS, forcing a move to alternatives.
• Plastic: Prohibited use of materials like microplastics and expanded polystyrene (EPS), and taxation models for Single-Use Plastics, such as with Phase 1 of the Canadian Plastics Registry, being implemented in 2025.
• Packaging: Major reform in EPR costs as part of implementing the EU’s Circular Economy Action Plan, including the Packaging and Packaging Waste Regulation (PPWR). Legislation is also evolving in emerging jurisdictions like Canada and the US, with regulations like the New Jersey Recycled Content Law
• Batteries: EU Regulation impacting material supply product design and recognising batteries role as part of the low carbon economy in products and electric vehicles (EV’s).
• Closed-loop recycling: A drive to achieve a more circular economy by retaining control of material, limiting international waste shipments, and banning export of certain waste materials thereby increasing costs of disposal and encouraging more investment into recycling (e.g, Basel Convention updates).
• Emerging policies: In markets where EPR previously did not exist, governments are rapidly rolling out measures to combat the challenges of product consumption and disposal and appease NGO, the public, and industry demands. For example, Singapore recently implemented new requirements, and up-and-coming nations in Latin America, like Chile and Argentina, are next.
• WEEE: Waste from Electrical and Electronic Equipment (WEEE) regulations are undergoing reform in some countries, such as the UK, with the interplay between future delegated acts for electricals under the EU ESPR also being of consideration to the regulatory landscape for waste electrics and producer responsibility.
• Textiles:  California has passed the first EPR regulation for textiles in the US that will require producers to manage the recycling and reuse of their products to address the growing textile waste problem.  This is expected to be implemented by 2030. 

Extended Producer Responsibility schemes are a vital part of any nation’s path towards achieving a circular plastics economy.

Kristin Hughes, Director – Global Plastic Action Partnership and Member

Common challenges for EPR reporting and engagement:

• Varying Regulations: Rules differ across regions and countries, complicating compliance for multinational companies.
• Data Management: Collecting and reporting accurate data on packaging, materials, and flows can be burdensome.
• Defining Responsibility: Ambiguity over whether the producer is the manufacturer, importer, or retailer.
• Ensuring Fairness: Free-riding by non-compliant companies undermines effectiveness.
• Compliance Costs: Often passed on to consumers.
• Monitoring & Enforcement: Strong regulation is required to prevent loopholes.
• Global Supply Chains: Differing requirements make consistency difficult.

Are you ready for EPR? What businesses should do now

The frameworks of requirements for EPR are quite similar, with a declaration of responsibility and financial fulfilment element that is linked to sales volumes. The main stages an organisation must follow are:

1. Qualify: Understanding your supply chains and routes to market, even before looking into the legal text of what requirements your organisation needs to meet.
2. Apply: EPR and similar product stewardship laws typically hold a registration requirement for obligated businesses to declare they have such responsibilities under the law.
3. Report: Regular reporting is necessary for EPR to quantify requirements. This step is important because it quantifies the costs for your organisation and is made on a declaration basis as an accurate and correct account of volumes by a business leader. In addition to data, information and takeback programmes may also be required for the consumer.
4. Review: Policies, targets, and requirements change, as does your organisation. These changes impact the requirements, scope, and costs to your organisation, so those responsible for compliance must remain on top of the latest updates. 

Extended Producer Responsibility services

Anthesis is strategically positioned in key global markets across the value chain to meet the specific needs of multiple industries. Our expertise in EPR consulting and product stewardship can be split into four main sections: strategy, compliance, implementation, and thought leadership.

• Strategy:  Developing a strategy for navigating the evolving EPR and EPR-adjacent regulations is critical for companies to understand their financial exposure and the roadmap to reducing their risk, ensuring compliance, and ultimately reducing their EPR fees.
• Compliance: Responsible sourcing, including conflict minerals due diligence requirements, supplier material compliance data management and analysis, and managing product and packaging takeback services, from data analysis to report construction and regulatory data submissions.
• Implementation: Developing innovative and disruptive business models, managing business process outsourcing and integrating software and systems like an EPR compliance management solution.
• Thought leadership: Providing analytics and reporting, research and development, and strategic communications.

Our product stewardship services ensure products meet global regulations and define clear strategies to achieve set standards. We also offer product sustainability impact assessments as part of our services to help brands create better and sustainable products.

Global EPR updates

Disclaimer: All dates are subject to change by the controlling entities. This site can be used as a reference but is not responsible for any information that may be recently updated or that is not provided here.   

Key legal frameworks globally:

• European Union: Most comprehensive EPR, covering packaging, WEEE, ELVs (end-of-life vehicles), batteries, and more.
• United States: Patchwork—states like Maine and Oregon have packaging EPR laws, while others do not. Most urgently, companies must have registered for California Reporting by September 5, 2025, through the Circular Action Alliance. California Reporting opens on September 15, 2025, and is due by November 15, 2025. 
• Canada: Strong provincial EPR (e.g., B.C., Ontario, Quebec). Canadian Plastics Registry Reporting is due by September 29, 2025, through the Regulatory Services Platform.
• Asia: Japan, South Korea, and China have robust EPR laws for packaging, electronics, and vehicles.

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