Europe extending the reach of EPR obligations
While member states are working hard to finalize their implementation of the WEEE Open Scope, the European Union is taking serious steps to introduce new directives on extended producer responsibility.
The first noteworthy examples are Directive 2018/851 and Directive 2018/852 on packaging and packaging waste. These directives will oblige member states to implement a system of extended producer responsibility by 2020. The current directive (94/62/EC) provides the option to do so, but it is not an obligation. This will have direct consequences for all European countries as the new directives also sets certain minimum requirements for EPR systems for packaging. One noteworthy aspect is the requirement for member states to allow the appointment of an authorized representative for packaging.
Additionally, the European Commission has presented a proposal for a new directive on single-use plastics. If this proposal is accepted and adopted as a directive, extended producer responsibility will apply to a larger group of plastic products. Examples of these products are food containers, tobacco products with filters and balloons.
It is not yet clear if or when this proposal will become actual legislation in Europe. It does indicate, in combination with Directive 2018/852, that Europe is not slowing down in their implementation of extended producer responsibility.
Are you as a producer uncertain about your current compliance for packaging? Or do you want to prepare yourself for the upcoming changes? Please get in touch with us. Our environmental team is always available to discuss your questions with regard to EPR.