In a policy brief, the environmental network argued that current EPR frameworks are too heavily focused on downstream waste management and recycling, and do not sufficiently support measures such as repair, reuse and refurbishment.
Reforming how EPR fees are structured could help address Europe’s stagnating circularity rate and unlock funding needed to scale circular business models, according to ZWE.
Split ring-fencing for EPR funding
The brief calls for EPR contributions from producers to be divided into two budgets: one dedicated to waste management operations and another ring-fenced for waste reduction measures.
Under the proposed model:
- Waste management fees would continue to cover the costs required to meet collection and recycling targets
- Waste reduction fees would be allocated specifically to systems and infrastructure supporting reuse, repair, refurbishment and other prevention-focused activities
According to ZWE, this approach would ensure that EPR schemes go beyond end-of-pipe treatment and actively contribute to lowering overall material use.
Thereas Mörsen, Waste & Resources Policy Manager at ZWE, explained: “The waste reduction fee should cover, for example, the budget necessary to achieve waste reduction targets, via reuse, repair, refurbishment and similar measures.”
Transition fund suggested until 2030
ZWE acknowledges that, in several Member States, there is currently limited data on the real costs of reuse and reduction systems, which could make it difficult to set an immediate, precise waste reduction fee.
As a result, it proposes a transitional measure running until 2030: a dedicated “fund for the transition to circularity”. Under this mechanism, a minimum percentage of Producer Responsibility Organisation (PRO) budgets would be earmarked specifically for reduction and reuse initiatives.
This would act as a bridge while better cost data and performance benchmarks are developed at national level.
ZWE says the fund could support measures such as local reusable packaging systems, repair networks and voucher schemes, many of which are currently reliant on public funding.
Legally binding targets needed
ZWE also stressed that stronger governance rules will be needed to ensure EPR money is used effectively if budgets are expanded or restructured. It has called for:
- Legally binding targets for PROs
- Transparent reporting on fee allocation and outcomes
- Clear oversight mechanisms to ensure funds reach circular business models
Mörsen added: “Most of the initiatives to boost reuse and repair today, be it repair vouchers or local reusable packaging systems, are financed by the public budget.
“As treasuries are increasingly under pressure, producers must, in line with the Polluter Pays Principle, bear a greater share of the costs of the transition to circularity.
“The general mindset is still pretty much stuck with protecting outdated linear business models instead of helping new ones to thrive.”
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