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Extended Producer Responsibility (EPR) describes environmental policies that makes producers responsible for the entire life cycle of their products, spanning from design to end-of-life management, including waste collection and recycling. EPR aims to ensure that producers actively engage in sustainable practices and decrease the total environmental impact from their products and packaging. In practice, EPR requirements can translate into a wide variety of obligations for the producers and resellers and can affect multiple product groups (non-exhaustive list).
Examples of EPR requirements
Collection fee for products, Collection rate targets, Carbon footprint declaration, Minimum content of recycled materials, Responsible sourcing of raw materials, Product passport, Performance and Durability requirements
Examples of product groups
Packaging, Batteries, Electronic products, Plastics, Furniture, Paints, Chemicals, Energy-related products, Iron, Steel, Cement, Aluminium
The first EPR policy appeared in the EU in the early 1980s and spread across different Member States. As a result of the EU’s commitment to climate neutrality, organisations are now facing greater challenges and responsibilities in meeting these evolving requirements. The implementation of EPR requirements at the EU level is usually structured in three ways:
Certain products, such as packaging, batteries, plastics and electronic waste, are subject to specific laws and regulations that outline mandatory requirements for environmental sustainability. These specific laws provide a comprehensive framework for regulating the life cycle of these products, ensuring their responsible management. The ‘Proposal for a regulation concerning batteries and waste batteries’ is one example of specific regulatory framework.
Products that do not have dedicated legislation mandating environmental sustainability requirements, such as textiles, furniture and paints, usually fall under the Eco-design for Sustainable Product Regulation (ESPR). This regulatory framework covers 31 different product groups, and serves as a comprehensive guideline for promoting sustainable design principles and practices.
Certain products, such as large-scale stationary industrial tools, do not have a specific legal framework governing their environmental sustainability obligations. These products fall outside the scope of the ESPR and are subject to alternative measures and strategies for ensuring their sustainable management.
Switzerland does not currently possess a comprehensive EPR framework similar to the ESPR. However, the country closely monitors new developments in the EU and has established specific requirements for certain products, such as batteries, packaging and electronic equipment. At present, Switzerland mainly enforces three forms of EPR obligations.
EPR requirements go beyond product compliance and fee payment obligations. The concept of circularity, especially EPR, needs to be embedded into the overall strategy of the company. For this purpose, we recommend a comprehensive five-step approach:
Evaluate: Gain a thorough understanding of the current sustainability level of the company's products, examining their environmental footprint and performance.
Understand and anticipate future trends: Analyse regulatory trends and observe the actions of competitors in order to identify potential future requirements and stay ahead of the curve.
Quantify potential impacts: Conduct an impact assessment to determine how the company might be affected by forthcoming regulations, considering costs, operational adjustments and resource allocation.
Establish objectives: Consult stakeholders and update the company's sustainability ambitions to align with evolving regulatory expectations, considering factors such as raw material sourcing, production efficiency, product use phase and end-of-life management. Establishing an interdepartmental working group is an excellent way to gather valuable insights address the EPR topic in a holistic manner.
Implement strategic changes: Identify key actions, assign deliverables to heads of relevant departments and monitor their implementation. These actions can take multiple forms, such as integrating sustainability targets into product design, establishing a data collection process in place that collects sustainability information across the entire value chain (data on raw material extraction, production, recycled materials, etc) and designing sustainable procurement policies at the group level.
Certain EPR related requirements stems from other regulatory initiatives and transcend product groups. Presented below are some examples of interlinkages between EPR requirements and other key sustainability topics.
The plethora of sustainability regulations and requirements imposed by regulatory bodies poses a significant challenge for companies. Effective governance and robust data management are essential to address these obligations. We highly recommend assessing your current position and potential gaps with the upcoming regulatory changes. Each company should evaluate the following points:
PwC actively assists clients across various sectors in embracing a holistic approach in order to comply with the ever-evolving sustainability regulations. Please contact us to discover how our team of experts can support you.
Senior Manager, Sustainability & Strategic Regulatory, PwC Switzerland
Tel: +41 78 696 32 11
Senior Manager Environmental Tax & VAT, PwC Switzerland
Tel: +41 75 413 1861