EXPRA EUROPE ASBL

This joint submission by EXPRA and EPRO provides feedback to the European Commission on the implementation of Article 7 of the Packaging and Packaging Waste Regulation (PPWR), covering the methodology for calculating and verifying recycled content in plastic packaging, sustainability criteria for plastic recycling technologies, and conditions for recognising recycled content imported from third countries. The two organisations support the establishment of a robust and harmonised framework to achieve the PPWR recycled content targets, while emphasising the need for complementary measures that ensure sufficient recycling capacity, market demand for recyclates, and regulatory certainty across…

This joint submission by EXPRA and EPRO provides feedback to the European Commission on the implementation of Article 7 of the Packaging and Packaging Waste Regulation (PPWR), covering the methodology for calculating and verifying recycled content in plastic packaging, sustainability criteria for plastic recycling technologies, and conditions for recognising recycled content imported from third countries. The two organisations support the establishment of a robust and harmonised framework to achieve the PPWR recycled content targets, while emphasising the need for complementary measures that ensure sufficient recycling capacity, market demand for recyclates, and regulatory certainty across…

This joint submission by EXPRA and EPRO provides feedback to the European Commission on the implementation of Article 7 of the Packaging and Packaging Waste Regulation (PPWR), covering the methodology for calculating and verifying recycled content in plastic packaging, sustainability criteria for plastic recycling technologies, and conditions for recognising recycled content imported from third countries. The two organisations support the establishment of a robust and harmonised framework to achieve the PPWR recycled content targets, while emphasising the need for complementary measures that ensure sufficient recycling capacity, market demand for recyclates, and regulatory certainty across…

EXPRA is the European Association of Extended Producer Responsibility Organisations (PROs), representing 25 organisations within 21 EU Member States and the European Economic Area which ensure that producers contribute to the costs associated with the life cycle and end-of-life management of their products, including collection, sorting, reuse, recycling. EXPRA supports a harmonised and enforceable system that provides reliable information on producers' compliance with extended producer responsibility obligations. The implementation of Article 44 should promote transparency, facilitate enforcement and ensure a level playing field across the Union, while avoiding disproportionate…

EXPRA EUROPE will engage in EU policymaking to provide technical expertise and operational experience on Extended Producer Responsibility (EPR) systems, contributing to the effective, efficient and practicable implementation of EU waste and circular economy legislation.
Packaging and Packaging Waste Regulation (PPWR)
EXPRA EUROPE will actively contribute to the implementation, secondary legislation and guidance under the Packaging and Packaging Waste Regulation (PPWR). It will aim to ensure that its targets are achieved in a manner that fully reflects the operational realities and proven performance of well-functioning EPR systems.
EXPRA EUROPE will work with its members to develop practical solutions to support implementation, particularly where harmonisation will be needed or requested by industry or policymakers (e.g. reporting requirements and the application of post-consumer recycled plastics). It will also seek to address market challenges faced by recyclers and promote approaches that enhance efficiency and reduce operational costs, while safeguarding environmental outcomes.
Circular Economy Act (CEA)
In the context of the forthcoming Circular Economy Act, EXPRA EUROPE will position EPR systems as core delivery infrastructure for circularity. It will advocate for realistic timelines, coherent governance frameworks and alignment with established high-performing national systems. EXPRA EUROPE will contribute to discussions on improving minimum EPR requirements to strengthen performance, transparency and accountability.
Environmental Omnibus
Regarding the Environmental Omnibus, EXPRA EUROPE will present its views and proposals during discussions in the European Parliament and the Council. It will support simplification measures that reduce administrative burdens for Producer Responsibility Organisations (PROs) and producers, while safeguarding transparency, effective enforcement and regulatory credibility.
Waste Framework Directive
In relation to the Waste Framework Directive, including potential revisions, EXPRA EUROPE will work to defend and strengthen the integrity of EPR principles, financing mechanisms and proportionate reporting requirements. It will advocate for preserving non-profit governance models that underpin many well-performing EPR systems and will seek to prevent regulatory changes that could undermine their effectiveness.