As the EU advances its new Circular Economy Act, concern is mounting over the increasing acceptance of state-run Producer Responsibility Organisations (PROs) in EU legislation. CEFLEX recently joined a wide coalition of more than 50 associations – coordinated by EUROPEN – in calling on EU policymakers to explicitly prohibit state-run PROs and uphold the core principles of Extended Producer Responsibility (EPR).
The joint industry statement warns that assigning producer obligations to government-run entities risks undermining transparency, weakening performance, and diverting EPR fees into general state budgets. This model threatens to undo progress on packaging circularity, especially in areas like flexible packaging that depend on effective collection and recycling infrastructure.
The coalition highlights that language in the revised Waste Framework Directive (WFD) and other recent legislation appears to legitimise PROs with no producer mandate – a clear contradiction of the minimum EPR requirements set out in Article 8a of the WFD. Evidence from Member States like Hungary and Croatia suggests that such systems underperform, risking non-compliance with EU recycling targets.
To safeguard circular economy progress, the joint statement calls on EU policymakers to:
- Explicitly prohibit state-run PROs in the upcoming Circular Economy Act
- Enforce the general minimum EPR requirements laid down in the WFD
- Engage with national authorities, particularly in Poland, where legislation is being drafted that could introduce a state-run PRO
With a vote on the revision of the Waste Framework Directive expected later in 2025, CEFLEX and its partners are monitoring developments closely. Ensuring that EPR remains producer-led is critical to deliver on the ambitions of the Packaging and Packaging Waste Regulation (PPWR) and enable the circular economy for all packaging materials.
Full list of signatories and supporters:
