Extended Producer Responsibility - or EPR - is a term used to describe a certain kind of regulation. When the law requires producers to be in part responsible for the end of their product’s life, it’s considered EPR.
In 1990, Thomas Lindqvist and his colleague Karl Lidgren submitted a report to the Swedish Environment Ministry. It's in that report that Lindqvist, now Associate Professor and Director of Research at Lund University, coins the term "Extended Producer Responsibility".
After his 1990 report, Professor Lindqvist continued to work producing reports for the Swedish Environment Ministry. In his 1992 paper "Towards an Extended Producer Responsibility - Analysis of Experiences and Proposals" we get the following quote:
...an environmental protection strategy to reach an environmental objective of a decreased total environmental impact of a product, by making the manufacturer of the product responsible for the entire life-cycle of the product and especially for the take-back, recycling, and final disposal.
Thomas Lindqvist, ‘Towards an Extended Producer Responsibility – Analysis of Experiences and Proposals’, 1992
It’s a little wordy, but I think it sums up EPR quite nicely. Collectively, we want to reduce the impact that the things we sell and buy have on the environment. Lindqvist argues that one way we can do that, is by making the product's producer an equal party in its disposal and recycling.
Lindqvist is quick to point out that whilst he “wrote the idea down and put a name on it”, he was far from the only person thinking about EPR in the 1990s. In Europe, the idea that governments shouldn’t have to bear the cost of waste management alone was growing popular.
Here in 2026, EPR is a catch-all term used to describe legislation built on the ideas of Lindhqvist's original policy suggestions. I’ve put some examples together in the following table. Some of these you might already be aware of, like the Waste Electrical and Electronics Equipment Directive (or WEEE).
| Region | Legislation |
|---|---|
| France | AGEC Law (Anti-gaspillage pour une économie circulaire) |
| Germany | Verpackungsgesetz (VerpackG), Elektro- und Elektronikgerätegesetz (ElektroG), and Batteriegesetz (BattG) |
| Netherlands | Environmental Management Act (Wet milieubeheer) |
| UK | Producer Responsibility Obligations (Packaging and Waste) Regulations 2024, Waste Electrical and Electronic Equipment (WEEE) |
| EU | Waste Framework Directive, Batteries Regulation, Waste Electrical and Electronic Equipment (WEEE), Packaging and Packaging Waste Regulation (PPWR) |
As you'll see, EPR adds some steps to the process of getting your product to market. Because of that, I find it helpful to understand why so many governments are adopting EPR regulations. The requirements make more sense when you know the problems they're trying to address.
In the last 70-ish years, the amount of waste we've been creating has drastically increased, particularly plastic waste. In turn, that has increased the stress on waste management systems.
While we've increased the quantity of waste we're making, we've also made it more complicated to manage. In a 2024 webinar, ‘History of Extended Producer Responsibility’, Professor Lindqvist gave the example of cadmium use in plastic production. Cadmium yellow has been a staple on artists pallets since the early 1800s. Cadmium-based pigments are lightfast, stable and vibrant, which makes them perfect for both sunflowers and packaging.
However, Cadmium - if you didn't know - is a toxic heavy metal. It’s poisonous and very dangerous to breathe in. Which you might have done, if you lived near a waste disposal site where they burnt cadmium yellow plastic packaging.
Packaging that used cadmium yellow presented a real problem for the people responsible for its disposal. How could it be disposed of safely, without harm to the environment or people? How could workers tell which yellow packaging was coloured with cadmium versus the safe alternatives?
Since the 1990s, cadmium pigments have been heavily regulated. In a way, these regulations are a form of EPR. They stop the problem at the source, rather than fund increasingly expensive and complicated systems to deal with the waste safely.
Clearly, we have a waste management problem. It’s expensive to collect, separate and recycling waste safely. The cost usually falls on governments and through them, taxpayers.
With that in mind, EPR regulations have two goals:
It does this by addressing the problem at one of its sources: product design.
At a high level, EPR compliance is a three-step process:
EPR regulation centres around whether you are considered a "producer" and therefore have the "extended responsibility". If you are a producer, you'll need to register, file and pay the contribution.
Producers introduce products to market, so you're considered a producer if any of the following describe you:
Producer Responsibility Organisations (PROs) are at the core of how EPR works day-to-day. They're government-approved bodies responsible for:
They're usually non-profits and essentially, they act as the link between producers, governments and waste management systems. When you're registering for EPR, you're joining a PRO as a member. In most countries, PROs have a registration fee, which you pay annually to be listed as a member.
Each country has its own PROs that cover the various product categories (sometimes multiple per category) they have regulated. For example:
Some countries, like Germany, run a dual system - you might have heard of LUCID, the German Packaging Register. When you register for EPR in Germany, you'll have to register with LUCID and then join the relevant PRO.
If you're not based in the EU, you're going to need an Authorised Representative (AR) to register for EPR. They are legal entity (or person) that you appoint to act on your behalf in the country where you’re registering. For example, if you decide to register for EPR with SimplyVAT, we'd be your authorised representative.
The AR acts as the connection between you and the Producer Responsibility Organisation. They’re jointly liable for your compliance - if you don't pay your fees, PROs can request they pay it instead.
From the 12th of August 2026, all non-EU businesses will require an AR to register for EPR in the EU. That's thanks to the Packaging and Packaging Waste Regulation.
Registration terms are a whole calendar year (January to December), with an upfront registration fee. If you register in the middle of a year, you should be prepared to report relevant activity from the start of the calendar year. For example, if you register in July, you'll likely still have to submit reports of say, your packaging data, back to January.
As with VAT compliance, you should be registered for EPR before you start selling. Once registered, you’ll be issued an EPR registration number.
Once you're registered, you'll need to submit your first lot of data. The specific details you need to provide will depend on the category you're applying for, but usually it includes:
You might also need to include things like the percentage of recycled content and the recyclability classification.
Your first report will be an estimate of the amount you expect to put to market, and the PRO will use that data to calculate your fee. This is separate to the registration fee. You might see these called "eco fees" and they're usually invoiced annually. However, it's not uncommon to see monthly, quarterly or bi-annual payment frequencies. It all depends on what you're registering for, and where.
Marketplaces like Amazon have to ensure that sellers on their platforms are compliant with EPR. This liability makes them particularly demanding when it comes to your compliance. For example, they’re likely to suspend your account if you can’t provide an EPR number when asked.
To make it easier for sellers, Amazon has a program called ‘Pay on Behalf’. In certain countries, Amazon will prepare and file reports for you, then pay the EPR fees on your behalf. They’ll then charge your seller account for the calculation, reporting and fees. Enrolment in the program is automatic, and currently works in:
If you opt to register for EPR yourself in any of these countries, you have to provide your EPR number to Amazon. They’ll stop preparing and filing your reports, as by adding your registration number to your account, you’ve assumed responsibility for it.
TikTok Shop also has a version of Pay on Behalf, which works in practically the same way.
In our June 2026 webinar, Jenny Budd and Liam Payne looked at EPR and what compliance looks like in practice. Watch it now to learn why EPR matters and how it impacts the ecommerce industry.
