Over 40 Industry Associations Call for a Stronger EU EPR Framework Under the Circular Economy Act

More than 40 industry associations, including EUROPEN, have signed a joint statement calling on EU policymakers to use the upcoming Circular Economy Act (CEA) to strengthen the EU’s Extended Producer Responsibility (EPR) framework. According to Packaging Europe, the signatories describe the CEA as a unique opportunity to build a functioning European market for secondary raw materials.

Their central argument is that the fragmentation of national EPR systems creates barriers to cross-border activity, discourages investment in recycling capacity and holds back a genuinely European circular economy.

 

The Priorities Set Out in the Statement

The joint statement sets out six priorities for the CEA. Among the key points:

1. A harmonized EU EPR Regulation based on Article 114 of the Treaty on the Functioning of the European Union (TFEU), the internal market legal basis, setting a common baseline for all EU-mandated EPR schemes, with sector-specific rules on top.
2. Producer-led EPR governance, with producers retaining decision-making responsibility and public authorities limited to oversight.
3. Transparent reporting across the waste chain, covering not only the schemes themselves but also the municipalities and authorities that receive EPR funds.
4. Targeted Use of EPR funds, directed to the waste streams they finance, with revenues from recovered materials deducted from producer costs.
5. Reduced administrative complexity, through harmonized registration limited to essential data. For packaging, authorized representatives would be required only from producers based outside the EU.
6. Stronger separate collection, with stricter obligations for Member States and EPR-funded public awareness campaigns.

 

The Evidence Behind the Call

The statement builds on a study commissioned by EUROPEN and carried out by CIRCPACK by Veolia, published in July 2026. The study found wide performance gaps between national packaging EPR systems across the EU and argued that these systems must be able to collect, sort and recycle packaging at scale if the PPWR’s targets are to be met.

The concern is practical. The PPWR sets harmonized design requirements and recycling targets at EU level, but collection, sorting and fee structures are still run through 27 separate national systems. If those systems perform unevenly, producers face different costs and outcomes for the same packaging depending on where it is sold.

 

 

A Recurring Theme in 2026

The statement adds to a growing body of industry calls around the CEA. In May 2026, BusinessEurope also called for the Act to be grounded in Article 114 TFEU and to deliver genuine harmonisation of EPR rules. Earlier in the year, companies including IKEA, LEGO and SAP called for an “ambitious” CEA that aligns regulatory requirements across the Single Market.

Not all stakeholders share the same view on the legal basis. Environmental organizations, including the European Environmental Bureau, have argued that relying solely on Article 114 could leave the Act without a sufficient mandate to address the environmental side of the circular economy transition.

The debate also connects directly to the ongoing discussion around the PPWR’s authorised representative requirement, where SMEs have argued that per-country obligations create disproportionate costs.

 

Conclusion

The Commission’s CEA proposal is expected in the coming months and it will show how far the EU is prepared to go in replacing 27 national approaches with a common framework. For producers placing packaging on multiple EU markets, the outcome could significantly change how EPR compliance is managed across borders.