A Comparative Analysis of EPR Frameworks in Some EU Member States

This table provides a detailed analysis of how EPR policies are implemented in six EU member states: France, Germany, the Netherlands, Portugal, Spain, and Italy. While operating under broader EU directives, each country has developed unique approaches to legislation, fee structures, and enforcement. This comparison showcases the nuances of mature EPR systems and offers valuable models for policy development in the U.S.

Criteria	France	Germany	Netherlands	Portugal	Spain	Italy
Year of Introduction of EPR as a law or policy	1975, Decree No 92-377; Article L.541-10 of the French Environmental Code¹	1991, German Waste Act²	1993, National regulation on waste management of End-of-Life Vehicles³	1997, Municipal Solid Waste Strategic Plan⁴	1997, Spanish Packaging and Packaging Waste Act⁵	1997, Ronchi Decree⁶
Key Legislations	2020 French Anti-waste and Circular Economy Law (AGEC)⁷ Environmental Code, articles L.541-10 and R.543-42⁸ 2019 National Waste Management Plan (NWMP)⁹ 2019 Law 2015-992¹⁰	2019 Packaging Act (VerpackG)¹¹ Circular Economy Act¹²	2018 Central Environmental Law Dutch Law on Packaging Waste 2014 Packaging Management Decree 2018 Dutch National Waste Prevention Plan National Waste Management Plan¹³	Decree Law 152- D/2017¹⁴ Decree-Law No. 102-D/2020 Decree-Law No. 24/2024¹⁵ 2017 Portuguese National Action Plan for the Circular Economy¹⁶	National Waste Framework Plan Law 7/2022 on Waste and Contaminated Soil for a Circular Economy Waste Framework Directive Royal Decree 1055/2022¹⁷	Decree no. 152 (152/06): Environment Regulations or Environmental Consolidated Act (ECA)¹⁸ Legislative Decree 116/2020¹⁹
Key Enforcement Agencies	The Ministry of Ecological Transition (Ministères Écologie Énergie Territoires)²⁰ French Environment and Energy Management Agency (ADEME)²¹	Federal Ministry for the Environment, Climate Action, Nature Conservation and Nuclear Safety²² Central Coordination Agency- Zentrale Stelle²³	Dutch Environmental Agency (PBL) Ministry of Infrastructure and Water Management ²⁴	Portuguese Environment and Climate Action Ministry, Environment Agency (APA)25	Ministerio para la Transición Ecológica y el Reto Demográfico (MITERD)²⁶ Ministry for Ecological Transition (MITECO)²⁷
Producer Responsibility Organizations (PROs)	Adelphe, Batribox, CITEO, Cyclevia, EcoDDS, ECOPAE, Léko, Pyréo²⁸	Der Grüne Punkt GmbH (The Green Dot), Landbell AG, Interseroh Dienstleistungs GmbH Reclay Systems GmBH, BellandVision GmbH, Zentek GmbH & Co. KG, Veolia Umweltservice Dual GmbH, Noventitz Dual GmbH, PreZero Dual GmbH²⁹	Verpact (formerly Afvalfonds Verpakkingen)³⁰	Nove Verde (recycling of packaging waste)³¹, Sociedade Ponto Verde (SPV)³²	Ecoembes (household and commercial), Ecovidrio (glass), Aspapel (commercial paper and cardboard), Procircular ³³	Consorzio Nazionale Imballagg or CONAI
Producer Obligations	Registration with eco-organizations to obtain UID, prevention and management of waste, adopt an eco- design approach for products, adhere to requirements for transparency on environmental and health impacts, mandatory use of the Triman logo with sorting instructions for transparency and public awareness, integrating repairability criteria into product design.³⁴	Registration and reporting with LUCID’s Central packaging register³⁵, transparency with data, producers exceeding the de minimis threshold must annually submit a declaration of completeness reporting the total weight of the sales packaging they have marketed, by material.³⁶ All packaging material must also meet recycling targets set for each product type. who comply with the EPR policy and contribute financially to a PRO can display the Green Dot symbol on their packaging. This signifies their participation in the recycling system and helps consumers identify responsibly packaged products.	Registration with Verpact for companies placing ≥50,000 kg of packaging; foreign importers without a Dutch entity must appoint a local representative. Paying eco-contributions based on packaging type and volume. Submission of annual reports on packaging types and quantities; estimation tools are available if exact data is lacking.	Registration with an authorised take-back system (“Sistema Integrado de Gestão de Resíduos de Embalagens ’, or SIGRE), labelling of packaging to inform consumers about recycling requirements, appointment of an authorized representative by foreign retailers to fulfil the obligations in Portugal.³⁷	Registration involves identifying applicable categories, gathering necessary documentation, submitting registrations with regional waste authorities and chosen PROs, and obtaining a producer number. Producers must declare annually the quantities of their products on the market and the waste management measures they have taken. This process is completed with financial obligations of paying fees based on reported quantities and set rates by PROs. Products and packaging must reflect labeling that indicates their recyclability or provides disposal instructions, complying with consumer information obligations under EPR. For products sold in Spain, this means that a Green Dot on all packaging is required.	Registration with CONAI, contribute financially to the collection, sorting, and recycling of packaging waste by paying fees to CONAI, and regularly report the volumes and types of packaging they place on the Italian market. The reporting frequency, monthly, quarterly, or annual, is determined by the total Environmental Contribution (EPR fee, which is bases on packing type and volume) declared for each material in the previous year.³⁸

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A Comparative Analysis of EPR Frameworks in Some EU Member States

Criteria

France

Germany

Netherlands

Portugal

Spain

Italy