March 2024

Rest-of-World (ROW) EPR

Since 1994, with the first EU Packaging Directive coming into force and thus, tentative steps towards producer responsibility being realised in EU member states, we have seen additional Extended Producer Responsibility (EPR) Directives and Regulations being introduced across Europe. This includes the Waste Electrical and Electronic Equipment (WEEE) Directive, Batteries Directive, Single-use Plastics Directive, plus other European country-specific laws covering other waste streams (such as textiles, furniture, printer paper and toys when these reach end-of-life).

As manufacturers have gradually gotten to grips with implementing and managing EPR compliance obligations for producer registration, take-back, recycling and compliance data reporting across Europe, we are now seeing a proliferation of EPR regulations being drawn up and brought into force in countries outside of Europe (Rest-of-the-World; ROW countries).

Whilst we do see some particular similarities in EPR regulations being introduced around the world with established European laws, there are also many important differences. For example, compliance obligations in US, Canada, Asia-Pacific, Latin America, Middle-East and Africa have high-level producer requirements regarding take-back and recycling which are broadly in alignment with the EU laws. However, as always the devil is in the detail. We almost always see unique product scopes, registration and reporting requirements, with country, state, and province laws varying considerably .

These many differences can make it complex and time consuming for producers to understand their compliance obligations and fulfil the highly specific requirements for each individual market where sales are made, placing strain on internal resources for time, budget, and personnel allocation.

What steps do I need to take to prepare for ROW EPR compliance?

In simplest terms:

• Stay on top of regulatory developments which place increasing obligations on the producer of in-scope products (particularly electrical and electronic equipment, batteries and packaging; these are the product streams where ROW countries are concentrating their EPR regulatory implementations)
• Be prepared to adapt to EPR regulations coming on-stream, including undertaking detailed legal compliance assessments based on your sales and supply methods so you know when your company is obligated as a producer in particular countries
• Develop and implement any necessary changes to your Enterprise Resource Planning systems so you are gathering the right data on your products to report to the regulatory authorities and recycling compliance schemes
• Make sure your staff are suitably aware and trained in the area of EPR so your company can implement manage and maintain regulatory compliance
  

EARN provides expertise on the specific and often unique requirements across the world and can answer your questions and help you arrange for all the compliance steps needed, including organising waste take-back and recycling through our Take-Back Team. This means your organisation can focus on your primary business and rest assured that EARN will take care of your compliance responsibilities in all regions where it is required.

If you would like to know more about how EARN can help you overcome the challenges of implementing and managing EPR compliance solutions across the world, just let us know!