Extended Producer Responsibility Alliance
EXPRA
EXPRA (EXTENDED PRODUCER RESPONSIBILITY ALLIANCE) is the umbrella organisation for packaging and packaging waste recovery and recycling systems which are owned by obliged industry and work on a not-for-profit basis. EXPRA acts as the common voice and policy platform representing the interests of all its member packaging recovery and recycling organisations founded and run by or on behalf of obliged industry. These national recovery organisations are pursuing similar goals, essentially finding themselves and their stakeholders in a similar situation. They have set themselves the task of relieving industrial companies and commercial enterprises of their individual obligation to take back used sales packaging through the operation of a scheme which fulfills these obligations on a nation-wide basis on behalf of their member companies. The aim is to ensure the management of packaging waste in line with the circular economy principles at the same time ensuring climate neutrality.
ID: 382147211686-77
Lobbying Activity
Response to Circular Economy Act
5 Nov 2025
EXPRA Key Recommendations for the Circular Economy Act Extended Producer Responsibility (EPR) is a cornerstone of the EUs circular economy and waste policy. As the EU prepares the Circular Economy Act, it must protect EPRs integrity so it continues to deliver environmental and economic value. EPR must remain producer-led, fair, and adaptable to challenges such as e-commerce and changing consumer behaviour. 1. Safeguarding the Integrity of EPR EPR systems must remain industry-led and operationally independent, not diluted into a general tax mechanism as suggested by the introduction of the State-run PROs concept. The foundation of EPR is that producersthose who place products and packaging on the marketare directly responsible for the full lifecycle of their products, including waste management. This responsibility drives efficiency, innovation, and environmental outcomes, which would be undermined if EPR is reduced to a simple revenue-generating tool. The WFD and PPWR enshrine these principles, identifying EPR as essential for waste collection, high recycling rates, and waste prevention. Shifting control to public authorities would weaken incentives for eco-design and resource efficiency. 2. Transitioning EPR Systems to the SGEI Regime Recognising EPR as a Service of General Economic Interest (SGEI) would allow Member States to tailor systems to national needs while meeting EU goals. This change can be achieved within current laws and would improve flexibility and effectiveness without adding major costs. 3. Transparency and Accountability in Online Sales E-commerce has exposed major EPR compliance gaps, especially from non-EU sellers. Online marketplaces should be responsible for ensuring all products meet EPR rules, reducing burdens on SMEs and ensuring fairness. Non-EU importers must also cover waste costs. Clear, enforceable rules and data audits are essential to prevent free-riding. Aligning the Digital Services Act with waste law would strengthen enforcement and consumer protection. 4. Consumer and Citizen Engagement Public participation is vital for a circular economy. Producer Responsibility Organisations (PROs), with public authorities, should lead campaigns on sorting, recycling, and waste prevention. Setting EU-wide communication standards and creating a shared EPR platform would improve coordination and consistency. 5. CO Performance Benchmarking All waste policies should be assessed for their CO impact to align with the EU Green Deal. Benchmarking based on carbon performance prevents unintended emissions and promotes efficient, climate-friendly resource use. 6. Fair and Neutral Treatment of Producers EPR must treat all producers equally. SMEs and micro-enterprises should not face unfair costs. Comparable packaging should pay the same fees by material and weight. Publishing transparent fee tables would ensure fairness and a level playing field. 7. Neutral Treatment of Commodities and Technologies EPR should remain material- and technology-neutral, focusing on environmental performance. Harmonised end-of-waste criteria across the EU are vital for consistent recycling and efficiency. A common definition of the end-of-waste point will support innovation and fairness. 8. Governance and Stakeholder Dialogue The Act should strengthen structured stakeholder dialogue, as set out in Art 8a of the WFD. Platforms should include municipalities, recyclers, social enterprises, and consumer groups, while decision-making remains with those legally responsible for meeting targets to ensure accountability. Conclusion These recommendations aim to keep EPR a core driver of the EUs circular economy. Maintaining its producer-led model, ensuring online compliance, and promoting citizen engagement, combined with CO benchmarking and fair, neutral treatment of producers and materials, will strengthen EPR, support innovation, and advance a sustainable, coherent Single Market across the EU.
Read full responseMeeting with Ewa Malz (Head of Unit Environment)
13 Oct 2025 · Omnibus
Meeting with Sirpa Pietikäinen (Member of the European Parliament)
4 Jun 2025 · Packaging waste recycling
Meeting with Aurel Ciobanu-Dordea (Director Environment)
29 Jan 2025 · Exchange on Circular Economy Act
Meeting with Nils Torvalds (Member of the European Parliament, Shadow rapporteur)
6 Sept 2023 · PPWR
Response to EU rules for the calculation and reporting of recycled content in single-use plastic bottles
30 May 2023
EXPRA is pleased to provide the following feedback on the draft. If a non-plastic (for example paper) label is a part of the bottle, the methodology requires that it is deducted from the weight of the plastic bottle. This is different to the Commission Implementing Decision (EU) 2019/665 establishing the formats relating to the database system pursuant to EP and Council Directive 94/62/EC on packaging and packaging waste, which considers packaging consisting of a predominant material and another material (such as a label) up to 5 % of the packaging weight to be considered a single material. Therefore, it may occur that in the standard reporting under 2019/665 a paper label is reported as part of the PET weight. The draft Implementing Decision thus requires packaging to be reported differently from this standard, thus increasing the administrative burden and introducing the risk of errors. In the draft the weight of all beverage bottles placed on the market may be adjusted in order to take into account imports, exports or movements to or from other member states. More clarity on this is needed in terms of what is expected the language differs from Implementing Decision (EU) 2021/1752 (calculation method for the collection of PET bottles), which leads to uncertainty about the corrections that are required. By way of comparison, in Art. 3.2 of the draft here it states: the weight of single-use bottles placed on the market may, where there are significant imports, exports or other movements within the Union of such bottles by operators or by natural persons for their own personal use, be adjusted in order to take account of such movements. We would highlight that trying to assess recycled content in bottles linked to free riders or imports / exports of natural persons would not, in practice, be possible. In relation to access to data, it is noted that all parts of beverage bottles are covered by food contact requirements. Please note: the label is not considered to be part of the food contact packaging. The recycled content target is set at 25 % under the SUPD and according to the draft Implementing Decision this is assessed for the whole bottle including the parts made of materials other than PET (i.e. the cap and typically also the label). However, currently it is not possible to use plastics other than PET for food contact applications. As 25% recycled content for the whole bottle weight must be met, and only its body is typically made from PET, this means that the real rPET content in the body of a PET bottle must be at least 3 percentage points higher for the target to be met. As the label of the bottle may not be food contact packaging, the methodology should consider an alternative reporting system for this. In our opinion, the detailed information required to report under the Implementing Decision is not currently available from organizations active in the supply chain that normally provide data, such as EPR schemes. Nor will it all be available as per Regulation (EU) 2022/1616. We believe that there will need to be a longer implementation period whilst new data capture systems and processes are set up. Any new processes should be standardized at a EU level. We use this opportunity to stress the importance of having a methodology for calculating recycled content from chemical recycling (mass balance) in the Implementing Act as a matter of urgency. This is particularly relevant for non-PET plastic components such as caps and labels (typically polyolefins) as chemical recycling would currently be the only source of food compliant recycled content for these. In addition, the absence of an agreed methodology is delaying investment decisions that will be required to meet this and other mandatory recycled content target in contact sensitive applications. In Annex I, formulas for calculation of recycled content refer to the terms bodies of bottles, caps/lids and labels/sleeves which terms need to be defined.
Read full responseResponse to Review of the requirements for packaging and feasibility of measures to prevent packaging waste
23 Apr 2023
EXPRA POSITION PAPER ON PPWR The Extended Producer Responsibility Alliance (EXPRA), representing 32 non-profit national EPR organizations across Europe and beyond, supports the Commissions proposal to review the current packaging and packaging waste directive (PPWD). We believe that it is of crucial importance to set up a forward-looking and ambitious regulatory framework for packaging waste management enabling national and local entities to implement effective and efficient packaging and packaging waste management systems. The adoption of realistic and holistic policies is necessary to ensure packaging functionality is safeguarded whilst contributing to reducing the climate and environmental impact of packaging. Not all circular policies have an equally positive effect on the climate, and a scientifically robust approach based on life-cycle assessments should be favored. Regulatory predictability is key to ensuring investment security, especially in waste management infrastructures. Therefore, we would like to offer a series of recommendations to enhance the proposal, based on the extensive expertise of our members in EPR, waste management, and data collection throughout Europe, as follows: The definition of the obliged part of the packaging value chain should be clarified to avoid fundamental changes in the structure and governance of all EPR systems. Targets on recycled content, reuse and refillable solutions should be set at a national level (like the current recycling targets) instead of at a company or unit level. Separate collection of packaging waste at source should be the preferred solution to be accompanied by other systems, such as DRS, allowing Member States to decide regarding the collection of packaging waste, taking into account local conditions, existing investments, and accomplishments. In relation to recyclability criteria, a traffic-light system tied to the costs of recycling could be introduced to simplify the eco modulation of EPR fees. It is important to carefully define recyclability at scale to avoid hindering innovative packaging and recycling solutions. The specificity of industrial and commercial packaging should be recognized, as the proposed Regulation has been drafted considering mainly household packaging. This also concerns the development of Design for Recycling criteria, the recycled at scale definition and the use of recyclates. A level playing field must be ensured tackling non-compliance of EPR obligations especially on online sales and online market places using existing legislation in some EU Member States. In light of the large amount of secondary legislation planned, connect the deadlines with the publication of the related secondary legislation while an EU technical committee on packaging and packaging waste must be established.
Read full responseMeeting with Delara Burkhardt (Member of the European Parliament, Shadow rapporteur) and The Coca-Cola Company and
16 Feb 2023 · Packaging waste
Meeting with Sirpa Pietikäinen (Member of the European Parliament)
30 Jan 2023 · Packaging and Packaging Waste Directive (PPWD)
Response to Sustainable Products Initiative
20 Jun 2022
EXPRA calls for regulatory consistency across Circular Economy legislations
Input to call for feedback on the Ecodesign for Sustainable Products Regulation (2022/0095(COD))
EXPRA backs the ambitions set by the European Commission’s Proposal for an Ecodesign for Sustainable Products Regulation (ESPR). This initiative will set the foundation for cross-cutting product policy and put the EU on track in meeting its sustainability and circularity goals.
As such, EXPRA supports the Commission’s intention maintain performance requirements for packaging under the Packaging and Packaging Waste Directive (PPWD, 94/62/EC), as indicated in recital 21Under the existing Directive, packaging design already faces a wide array of requirements which are to be strengthened and expanded under the revision of the Directive. Additional obligations for packaging could indeed lead to disproportionate burdens for the manufacturing industry. Only a continued clear-cut approach will ensure consistency for economic operators regarding design and performance requirements of packaging as a final product.
With regards to product-based requirements focusing on the packaging of specific products covered by the ESPR, EXPRA believes that packaging must continue to ensure the protection of the product, thus extending its lifecycle and contributing to the EU’s emission reduction goals. This is the purpose of packaging and the PPWD must be the only legislation which can achieve a coherent approach to packaging design and sustainability, without hampering the internal market through different technical requirements. Indeed, the PPWD provides for essential requirements for packaging. With its upcoming revision, further essential requirements are to be included, enabling for all types of packaging format to contribute to the sustainability goals set by the European Commission.
In light of existing targets and their ongoing revision under the PPWD, EXPRA also calls on the EU Legislators to ensure that the complementing measures for the packaging of specific measures under the ESPR are consistent with the requirements of the PPWD, and do not counteract the circularity and emission reduction goals of the EU. This is critical to avoid confusion and unintended effects in the implementation of the future legislations.
As such, EXPRA calls on the Commission to ensure a well-gauged approach to the performance requirements of the different product groups with regards to their packaging.
Read full responseResponse to Waste Framework review to reduce waste and the environmental impact of waste management
22 Feb 2022
A future-proof legislative framework empowering EPR schemes to improve waste management
EXPRA’s response to the call for evidence on the Waste Framework Directive Revision
EXPRA supports a forward looking and ambitious regulatory framework for waste management which enables national and local entities to implement sound and efficient waste management systems. Waste that is properly collected, sorted and consequently recycled can bring further value as a resource to our society. EXPRA and its members stand by their commitment to make the Circular Economy Action Plan a reality at the same time contributing substantively in reducing CO2 emissions.
Executive summary
In our comments below, EXPRA aims to give an overview of key issues relevant for the sector. The Waste Framework Directive revision gives an opportunity to further strengthen EPR schemes and their role in our environmental transition.
• Enforcement of the waste acquis is of utmost importance before setting new requirements and targets on top of the ones that should be in force. Specifically, for EPR related to packaging, Member States where other waste streams are collected separately show the best results. This is especially important for the separate collection of biowaste. The timely enforcement of current waste legislation is critical to enable the sector to achieve best waste management practices.
• EPR principles should be duly enforced to enable certainty and consistency across Member States. This will favor the creation of a single market for waste with a view to foster recycling. However, the national level must maintain the operative command over the organization and coordination of its waste collection and sorting. EPR Organizations must have a (co-)responsibility in separate collection, sorting and recycling.
• Consumers’ and citizens’ involvement is central to achieve circularity goals. Respectively adequate communication, education and raising the awareness of the inhabitants towards environmentally friendly behavior are key in this respect. Packaging Recovery Organizations (PROs) are actively involved in such activities both separately or jointly with National or local authorities and developing minimum standards for such communication for respective stakeholders (EPR organizations, municipalities, education institutions, etc. could further facilitate and support this process).
• Greater transparency and accountability by the online-sales sector is needed regarding EPR obligations to enhance the transparency and data accuracy in waste management practice across the EU. This is why online sales should be explicitly covered under the new EU waste legislation. Non-EU importers of products which are sold in the EU must be accountable for the waste generated, and contribute to the long-term working of EPR systems.
• Reusable packaging should be registered under EPR. There should be a requirement to report and register reusable packaging so that it ensures a better understanding on the level of reuse and its performance. This could be promoted by economic instruments at a later stage.
• Each EU and national waste management measures must be benchmarked against their CO2 performance to ensure that it does lead to counterproductive effects on overall CO2 emissions of the sector. This will ensure the adoption of measures which make sense with regards to the overall objective of the Green Deal.
The full document is enclosed.
Read full response18 Jan 2022
The Extended Producer Responsibility Alliance (EXPRA) welcomes the revision of Regulation 282/2008 which should result in the necessary certainty for the recycled plastic supply chain and users of recycled plastics in food contact applications. This supply chain includes EPR schemes who play a vital role in the supply of high quality sorted plastic packaging to recyclers producing food contact grade recycled plastic. We have reviewed the draft Regulation and provide comments in the attached document.
Read full responseMeeting with Florika Fink-Hooijer (Director-General Environment)
11 Jan 2022 · Waste and Packaging
Response to Calculation, verification and reporting of data on the separate collection of SUP beverage bottles
17 Jun 2021
Packaging Recovery Organisations, including the 27 members represented by the Extended Producer Responsibility Alliance (EXPRA) as well as CITEO and Altstoff Recycling Austria AG (ARA), would like to comment on the proposed methodology for the determination of the weight of separately collected waste single-use bottles (Article 2 of the draft Implementing Act).
Said Article establishes the measurement point at output sorting, therefore introducing a calculation that should factor in losses within sorting operations.
The above implies that the Implementing Act is de facto shifting the collection target to a sorting – recycling one. This is problematic for the following reasons:
Determining the weight of separately collected bottles at output sorting entails accounting for inherent losses occurring during sorting processes. Losses are inevitable in any industrial process and may well vary depending on the efficiency of sorting plants. In any event, the sorting losses occurring during these operations do not relate to the material having been collected or not.
This shift would not be permissible within the framework of an Implementing Act given that it cannot amend or supplement a basic legislative act.
In sum, in the context of the SUP Directive, separate collection aims for packaging items to be diverted from litter, for which a collection methodology deducting sorting losses would not be justified.
OUR PROPOSAL
1. We believe that the measurement point for all collection modalities, including DRS, should be set at input sorting or, alternatively, at the output of sorting operations provided that:
a. Waste single-use plastic beverage bottles collected together with certain types of other waste measured at input sorting are determined by means of representative sampling and analysis, the methodology of which should accommodate for the necessary variations, or any other method, in agreement with public authorities and detailed in local agreements with EPR schemes.
b. Waste single-use plastic beverage bottles collected together with certain types of other waste measured at the output of sorting operations apply a correction factor based on sorting efficiency or standard losses (resembling the process defined in the IA for separately collected bottles under paragraph 6 of Article 2).
c. Traceability is, in all cases, guaranteed through to recycling, thus ensuring that the collected bottles are effectively recycled, and the following procedures performed:
i. The establishment of minimum efficiency rates for sorting plants, applied to both overall and material-specific performance.
ii. Quality controls based on sorting specifications.
iii. Third-party audits.
Please find enclosed our full response to this consultation.
Read full responseResponse to Review of the requirements for packaging and feasibility of measures to prevent packaging waste
6 Aug 2020
The Extended Producer Responsibility Alliance (EXPRA), representing industry-owned, non-profit packaging and packaging waste recovery and recycling organisations, welcomes the opportunity to provide feedback on packaging waste prevention and essential requirements as part of the EU consultation on the PPWD review.
EXPRA supports prevention goals within the PPWD, which the essential requirements should promote by, inter alia, reinforcing packaging design circularity.
Packaging waste generation represents less than the 4% of the total waste generation, of which 80% fed circular economies (67% via recycling and 13% via recovery) in 2017[1].
We believe that packaging has an important role in meeting the objectives of the Green Deal as well as climate neutrality targets through material efficiency and reuse/recycling, as well as protecting the products they contain and to extend their shelf life. However, we deem it important that any measure proposed as part of the PPWD review recognise role and responsibility of EPR organisations, and is proportional to the “problem” and cost-effective, avoiding increased complexity, or additional burden, for the industry.
The full document with EXPRA's views is attached.
Read full responseResponse to A new Circular Economy Action Plan
20 Jan 2020
The Extended Producer Responsibility Alliance (EXPRA) welcomes the Commission’s European Green Deal approach and in particular its work on the Circular Economy Action Plan (CEAP). We are particularly pleased to see that the Commission recognises the need to strengthen Extended Producer Responsibility (EPR) across sectors as this will reinforce the transition to a circular economy.
EPR is an important tool that helps Member States to move towards prevention and more sustainable waste management. Given that EPR is implemented in a variety of ways across the EU, incorporating the EPR principle appropriately into EU waste legislation and setting clear minimum requirements for EPR schemes was an important step.
As stated in the European Green Deal Communication, the correct implementation of current legislation is key for success. In this respect, we need to work together to ensure that the EPR requirements are now adequately transposed, implemented and enforced in order to effect positive change.
At the same time, the interpretation of provisions within the Waste Directives is still too broad in our opinion. We therefore believe that the Commission should focus on providing a clear and workable guidance to Member States with a view to harmonising the transposition, while acknowledging national specificities. As a starting point, the guidance should primarily strive for safeguarding the Internal Market while taking into account the roles and responsibilities that the various value-chain stakeholders have to perform so as to improve the EPR ecosystem, as per the letter of the waste legislation.
In addition, we welcome the focus on eco-design. Through EPR, producers are encouraged to pursue an efficient end-of-life management for their products. In turn, this leads to designing products that are easier to dismantle, reuse and recycle.
The eco-modulation of EPR fees will help EPR schemes go deeper into this direction. In order for this to be done in an efficient and effective manner, we believe that EPR schemes should be able to modulate according to a number of sustainable criteria and attributes that are adequate for their national situation and based on reliable data. Certainly, common EU guidelines on the modulation will prove crucial in helping Member States to ensure coherence in the Internal Market.
In this regard, we welcome the life-cycle assessment approach, which allows to determine the environmental impact of a product. By understanding the effect of the end of a life cycle, the manufacturer can work on manufacturing processes that reduce the danger to the environment and make the product safer to dispose of. Considerations on performance of packaging (to avoid product loss, for example) should also be taken into account when taking decisions about packaging.
Official standards from the European Standardization Organizations should be encouraged to ensure safety and quality for our products and services, too. Mandating the European Committee for Standardization (CEN) with the development of such standards represents a gain of time as the procedure is quicker than secondary legislation.
All things considered, clarification and further development of EPR rules should be based on robust independent scientific data and methodologies. This applies to further regulatory reviews that are being envisaged. Any additional policy measures should be consistent with previous experience, and allow for proper implementation of the recently-adopted objectives and requirements for EPR stakeholders.
Finally, we believe that linking the CEAP to the EU Industrial Strategy is important as industry plays a key role and should be part of the solution. We consider that a better balance should be sought for in terms of linking the economy, the environment and natural capital, without losing sight of our industry’s competitiveness.
For additional information, please see the attached document.
Read full responseResponse to Reducing marine litter: action on single use plastics and fishing gear
23 Jul 2018
Please find attached our views on the Commission's proposal for a Directive on the reduction of the impact of certain plastic products on the environment, and impact assessment.
Read full responseMeeting with Helena Braun (Cabinet of First Vice-President Frans Timmermans)
8 Jun 2018 · discussion on single use plastic legislation
Meeting with Sarah Nelen (Cabinet of First Vice-President Frans Timmermans)
23 Apr 2015 · circular economy
Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella), Heidi Jern (Cabinet of Vice-President Jyrki Katainen)
23 Apr 2015 · Circular Economy
Meeting with Sarah Nelen (Cabinet of First Vice-President Frans Timmermans)
23 Apr 2015 · Circular Economy