EPR – Extended Producer Responsibility

Extended Producer Responsibility (EPR) is an environmental policy principle under which the manufacturer or importer of a product bears financial and organizational responsibility for managing that product at the end of its life — i.e., once it becomes waste.

In practice, this means that a company placing a product in packaging on the market contributes to a system that ensures the collection, sorting, and recycling of that packaging after the customer has used and discarded it.

How EPR Works

EPR systems operate through collective schemes — manufacturers and importers register with an authorized organization (in the Czech Republic, for example, EKO-KOM), report the volume of packaging placed on the market, and pay fees based on volume and material type. These fees fund collection points, sorting lines, and recycling capacity.

Key principle: the more packaging waste a company generates, the more it pays. A company placing 10 tonnes of plastic packaging on the market per year pays significantly more than one placing 1 tonne — regardless of whether the packaging actually ends up being recycled or in a landfill.

Who is a “Producer” under PPWR?

PPWR defines a producer as the economic operator who first places packaging or a packaged product on the market of a given EU Member State. This definition has several important practical implications:

A packaging manufacturer supplying into the EU: If a packaging manufacturer sells empty packaging directly to the Czech Republic or another EU Member State, they are the producer — because they are placing packaging on the EU market for the first time. The EPR obligation applies to them regardless of where they are based.

A company purchasing empty packaging and filling it with goods: If you purchase empty packaging from a supplier who has already placed it on the EU market and paid the EPR fee, your obligation is fulfilled — it was met by your packaging supplier.

A company that manufactures packaging for its own use (and subsequently fills it with products): If you manufacture packaging for your own use and then fill it with goods, you become a producer under PPWR and are responsible for paying the EPR fee. If you sell unused packaging to another EU company, you remain the party responsible for the EPR fee.

Non-EU Packaging Suppliers: Authorized Representative

A company based outside the EU that places packaging on the EU market is required under PPWR to appoint an authorized representative — a legal entity established in the EU that fulfills EPR obligations on its behalf.

In practice, if you purchase empty packaging from a manufacturer outside the EU (e.g., from Turkey or China), you should verify:

• Whether your supplier has appointed an authorized representative in the EU;
• Whether that representative is registered in the relevant EPR scheme (in the Czech Republic, currently EKO-KOM);
• Whether the EPR fee for packaging delivered to the Czech Republic is actually being paid.

If a non-EU supplier fails to meet this obligation and you continue to use or sell the packaging, the practical compliance risk falls on you — even though the legal obligation formally rests with the supplier. It is therefore advisable to address this risk directly in your contract with the supplier.

Note: For companies established in the EU, the European Commission proposed at the end of 2025 to suspend the obligation to appoint an authorized representative until 2035. This exemption does not apply to non-EU suppliers (e.g., from Turkey or China) — their obligation remains in force.

EPR and PPWR

PPWR harmonizes EPR systems across the EU and introduces two key changes compared to existing national systems:

• Fee modulation based on recyclability – from 2028, EPR fees will begin to depend on the recyclability performance grade of packaging (grades A, B, C under PPWR criteria), with full implementation of this system expected by 2030. Packaging that is difficult to recycle (multi-layer materials, mixed plastics) will be subject to higher fees. Packaging made from a single, easily recyclable material will be cheaper.
• Exemption for reusable packaging – returnable packaging circulating in a closed industrial loop does not become packaging waste after each use. EPR fees therefore apply in a significantly more limited way — packaging is reported to the system once upon first being placed on the market, not with each cycle.

What EPR Means for Industrial Packaging Buyers

As a buyer of empty industrial packaging (e.g., transport crates or KLT boxes) who does not place it on the market as a packaged product, you do not directly pay EPR fees — the obligation rests with your packaging supplier.

However, EPR affects you indirectly in two ways:

• Packaging prices will rise – suppliers will pass EPR costs on in their pricing. Single-use packaging will become more expensive than returnable alternatives.
• Customers will ask questions – your buyers may want to know whether the packaging they receive from you comes from a supplier registered in the EPR system and whether that supplier is meeting its obligations.

Related Terms

• PPWR – EU regulation that harmonizes and tightens EPR systems
• Returnable packaging – a direct route to reducing EPR costs
• Scope 3 – EPR costs incurred by a packaging supplier may feed into the buyer’s Scope 3 reporting