EPR Essentials: A Guide to Extended Producer Responsibility (EPR)

Plastic has transformed how we live, shop, and consume. It’s lightweight, durable, and everywhere -  but those same qualities make it one of the hardest materials to manage once it’s thrown away. Across the world, policymakers are asking a simple question: who should pay to responsibly manage and process all that plastic once it becomes waste?

The answer is driving a new wave of laws built around Extended Producer Responsibility (EPR) - a regulatory framework that makes producers responsible for the plastic they produce and what happens to their packaging after use. It’s reshaping how companies design, package, and account for their products.

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1. What EPR means for plastic producers

Extended Producer Responsibility (EPR) laws, which are based on the ‘polluter pays’ principle, makes companies responsible for managing their plastic products and packaging throughout their lifecycle, including the post-consumer stage. The OECD defines EPR as a policy approach that shifts the responsibility (physically and/or economically; fully or partially) upstream to producers, and provides incentives to producers to take into account environmental considerations when designing their products. (OECD, 2024). This may include incentives to use alternatives, to reduce the amount of virgin plastic they use, and to make products more easily recyclable or re-usable. 

That shift matters because plastic waste has long been managed and paid for by local governments using taxpayer funds, a significant challenge for developing markets in particular, where other critical services such as healthcare and education are already underfunded. Under EPR, producer fees finance not only collection, sorting, and recycling, but also reuse/refill pilots, litter prevention and cleanup, take-back logistics, public education, market development, data systems and audits, and program administration and enforcement. The intended result is a steadier, ring-fenced flow of funds to invest in and scale these services.

In practice, that means:

• Companies register as "producers."
• They report the volume and type of plastic packaging they place on the market.‍
• They pay fees, often called “EPR fees” or “compliance fees”, based on how much they sell and how recyclable that packaging is.
• These fees are ideally redirected to investments in infrastructure and operations to improve waste management infrastructure and operations

The better your packaging design and management, the lower your EPR compliance fees.

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2. Why plastic packaging is EPR’s front line

Plastic packaging makes up nearly 40% of global plastic production, and most of it is used only once. Only a small fraction is recycled. The United Nations estimates the equivalent of over 2,000 truckloads of plastic waste is dumped into oceans, lakes and rivers every day.

Because packaging waste is so visible, and so often mismanaged, it has become the primary focus of EPR laws. Today, countries from the Philippines and India to the UK, EU, and several US states are using the ‘polluter pays’ principle to tackle plastic pollution. For example:

• India’s 2022 Plastic Waste Management Rules made EPR mandatory for brand owners, producers, and importers of plastic packaging.
  
• The Philippines’ Extended Producer Responsibility Act of 2022, required obliged companies to recover 40% of their plastic footprint in 2024, rising to 80% by 2028.
  
• The European Union, an early mover on packaging EPR years ago, has now sought to develop more harmonized rules in the forthcoming Packaging and Packaging Waste Regulation (PPWR).
  
• In the US, seven states, including California, Colorado, Maine, and Oregon, have passed packaging EPR laws.
  

Each system has somewhat different primary objectives and mechanisms, but the goal is the same: to make the cost of responsibly managing plastic part of doing business.

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3. Who pays to clean up plastic waste under EPR laws?

Across jurisdictions, EPR laws require producers to finance or organize end-of-life management for packaging, either through fees paid to stewardship schemes or through earmarked levies, which can cover collection and sorting, recycling and recovery, reuse/refill systems, deposit-return and take-back logistics, and more.The “producer” is defined as the company that first places a packaged product on the market.

That usually means:

• The brand owner whose logo appears on the plastic packaging.
  
• The importer bringing packaged goods into a country.
  
• The retailer or e-commerce platform selling under its own label.
  

It doesn’t matter whether the company physically manufactures the packaging; what matters is whose name it carries. This clarity prevents “free-riding” - when local governments and recyclers are left to manage unclaimed waste.

Tip: If you sell consumer goods in multiple countries, assume you’ll be classified as a producer in each, and that reporting rules will vary.

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4. PROs: How EPR schemes manage plastic recovery

Once producers are legally responsible for the plastic they put into the market, the question becomes: how does recovery actually happen? That’s where Producer Responsibility Organizations (PROs) come in.

What a PRO is

A Producer Responsibility Organization, often called a compliance scheme or stewardship organization, is the backbone of any EPR system. Instead of each company running its own waste program, producers pool resources through a PRO that coordinates everything from fee collection to recycling contracts and even reporting of compliance to the government agency overseeing the EPR program for that jurisdiction. Think of a PRO as a shared service that handles the logistics, financing, and reporting of plastic recovery on behalf of its members.

How a PRO works

1. Producers register and report
Companies join a PRO and declare how much plastic packaging they place on the market, broken down by type (PET bottles, HDPE containers, multilayer films, etc.), weight, and recyclability.

2. The PRO collects and manages fees
Each member pays an EPR fee proportional to its plastic footprint ( how much packaging they place on the market.)These pooled funds finance the collection, transport, and recycling of post-consumer plastic waste.

Fees are often “eco-modulated,” meaning recyclable materials pay lower rates, while difficult-to-recycle plastics pay higher ones. This pricing encourages more environmentally friendly design choices.

3. The PRO builds partnerships
The organization contracts waste collectors, materials recovery facilities ( MRFs), and recyclers to ensure plastic is collected and processed in line with jurisdictional ( national or state) targets.

In many emerging markets, PROs also work with local governments and informal waste workers to strengthen collection systems and ensure traceability.

4. The PRO tracks, verifies, and reports
Every tonne of recovered plastic is recorded, audited, and reported to the national authority. These reports confirm whether producers - collectively, through the PRO - have met their recovery targets for the year.

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Why PROs matter

Without PROs, EPR compliance would be unmanageable. They provide the scale and transparency needed to run efficient national recycling systems, and they allow producers to meet obligations collectively rather than individually.

For governments, PROs are a bridge between policy and implementation ensuring that EPR laws translate into real-world plastic recovery, not just paperwork. For companies, joining a well-run PRO brings consistency, verified data, and a credible path toward circularity. Some jurisdictions mandate a single PRO to represent all producers, while others allow for multiple PROs which producers can choose from. It is therefore critical to understand the rules in each EPR jurisdiction, and do your homework on the most trusted and reliable PROs where multiple PROs are authorized to operate.

In short: A PRO is the operational engine of EPR, turning individual producer obligations into a coordinated effort to collect fees, deploy resources and enable responsible collection, recycling and other packaging-related initiatives.

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5. What EPR means for businesses

For brands, EPR isn’t just another compliance box, it’s a signal that the era of disposable packaging is ending.

Companies that start early will find three big advantages:

1. Cost control: understanding your plastic data helps forecast EPR compliance fees and identify materials to redesign.
   
2. Regulatory readiness: transparent reporting and traceable data protect against penalties or shipment blocks.
   
3. ESG credibility: measurable recovery shows investors and consumers you’re taking responsibility, not just talking about it.
   

To get ready:

• Map where your plastic packaging is sold.
• Gather basic data: weight, resin type, recyclability.
• Check registration deadlines in each market.
• Identify credible PROs

These steps set you up for Part 2 of this series, EPR Data and Reporting for Plastic Packaging: A Step-by-Step Guide, which covers what data to track, how to structure it, and why it matters.

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Key takeaway

EPR for plastic packaging is here to stay. It moves the cost of cleanup from the public to the producer, and rewards companies that design packaging to stay in circulation, not end up in the environment.

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Simplify EPR packaging compliance, everywhere.

PCX’s global platform and local experts help companies simplify their EPR compliance in every market. Explore our solution →

‍Explore our EPR essentials series:

• EPR 101: A Guide to Extended Producer Responsibility
• EPR Reporting Made Simple: The Core Data Every Producer Needs to Capture

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FAQs

Q1. Why do EPR frameworks focus on plastic packaging first?
It’s the most common and most visible form of waste, and a major source of marine pollution.

Q2. Are EPR fees the same everywhere?
No. Fees depend on the weight and recyclability of your plastic packaging, and the compliance fee structure of the EPR jurisdiction you are operating in.

Q3. Can brands work with cleanup projects outside their main markets?
Sometimes. Many EPR systems allow verified recovery projects to offset domestic obligations when local recycling infrastructure is limited.

Q4. What happens if companies ignore EPR?
They risk fines, delisting by retailers, and reputational damage. In some countries, products can’t be legally sold without EPR registration.

Q5. Where can I learn more?
Start with the OECD’s EPR guidance and your local environmental agency’s EPR portal. For example, in California, you can visit the Circular Action Alliance CAA website. PCX also offers a plastic responsibility platform for EPR support and guidance. Click here to see how we can help.