What is Extended Producer Responsibility, also known by the acronym EPR?
It was the year 1990 and the Swedish academic Thomas Lindhqvist, who first introduced this concept, defined it as an “environmental protection strategy […] that makes the producer of the product responsible for the entire life cycle of the product itself and especially for its take-back, recycling and final disposal”. In other words, it is a notion that gives the producer financial and operational responsibility for the waste produced, requiring him to take care of its collection, sorting and treatment for recycling or re-use.
The direct consequence of this responsibility is the need for forward-looking and smart design that considers the environmental impact of the product at every stage, even and especially at the so-called ‘end-of-life’ stage.
Extended Producer Responsibility: legislation
Over the last two decades, the concept of EPR has become one of the European legislator’s main tools for managing many streams of waste in Europe. In particular, 2018 saw the enactment of Directives (EU) 2018/851 and 2018/852, two of the four pillars of the European Circular Economy Package, which aims to change the traditional linear ‘buy, use, consume and throw away’ model of the economy to a more sustainable model in which waste becomes raw material and generates new value on the market.
Common goals therefore for all member states, but it is the governments of each country that have to adapt them to specific national contexts, choosing between different implementation systems. Some examples?
France and Germany: examples of EPR systems
The best examples are currently to be found in France and Germany where, as of January 2022, marketplaces are legally obliged to verify the compliance of the EPR registration number of products traded on national soil.
But what is an EPR number and which products categories are subject to this regulation?
An EPR registration number is a unique identification number (UIN) that is given to a product that meets all the requirements in force for its category in the reference country. Requirements and categories vary from State to State and therefore there is no single EPR number for the European Union. This means that if we want to manufacture, sell or import a product in several countries, we will have to register our product in all the markets we are interested in, otherwise we will not be able to market it (or face a heavy penalty!).
As regards the product categories, they also change from one country to another: here are those for which it is currently mandatory to have an EPR number in France and Germany.
EPR product categories in France
- electrical and electronic equipment (WEEE)
- packaging (primary and secondary)
- printing paper
- vehicle tires
- writing paper
- textiles and footwear
- medical devices.
EPR product categories in Germany
- packaging (primary and secondary)
- electrical and electronic equipment (WEEE)
- temperature exchange equipment
- screens, monitors and equipment containing screens with a surface area of more than 100 cm2
- large equipment: with any external dimension exceeding 50 cm
- small equipment: with any external dimension not exceeding 50 cm
- small IT and telecommunications equipment with any external dimension not exceeding 50 cm
- batteries: portable, industrial and automotive batteries.
As you can see, the categories are not exactly the same in the two countries, but the differences do not end there: while France opted for an ‘integrated’ model, Germany relied on a ‘dual’ model. And what does it mean? Basically, in an integrated system the task of waste management is entrusted to the local authorities and the producer is required to contribute to the costs of waste management, whereas in the dual system it is the producer itself that has to arrange the sorting and disposal of its waste, relying on organizations (bodies or consortia) that on their behalf bear the full costs of collection and disposal and fulfill all EPR obligations.
Another observation of particular interest to us is that the only country where a system of Extended Producer Responsibility for textiles is currently applied is France. But how exactly does it work?
Extended Producer Responsibility for textiles: the French case
In France, the recovery and recycling of textile waste is carried out in practice by Refashion-EcoTLC, a private non-profit company created in 2008 and the only sectoral consortium accredited by French institutions. It is led by a board of industrialists and has more than 5,000 member companies. It provides assistance for the prevention and management of textile end-of-life products and coordinates the different actors involved in the chain. In addition, it conducts R&D activities to bring sustainable innovations to the textile industry.
The running costs of this organization are covered by the compulsory contributions paid by French textile producers. Small producers, i.e. those companies that do not exceed 5,000 articles or 750,000 euro turnover per year, pay a fixed fee, while for the others the contribution is diversified on the basis of product size and eco-design logics adopted. In fact, a 25% quota reduction is due for those companies that commit to extend the life cycle of their products and use recycled fibers and/or materials.
The results obtained through this system look promising: in 2019, some 250,000 tonnes of textile waste were collected, out of the 648,000 tonnes of textile products placed on the market, with a collection rate of 38%. A strongly increasing figure, if we consider that the collected tonnes are 100,000 more than in 2009.Of the total amount of waste recovered, 58% was reused, 33.5% recycled, 8% used for energy recovery and only the remaining 0.5% went to incineration.France therefore has an average of 3.7kg of fabric recovered per inhabitant, about 1.1kg more compared to Italy.
So could this be an example to follow, an EPR model that could also be applied in our country?
Italy: EPR in the textile sector
In Italy there is still no decree implementing the European regulation on Extended Producer Responsibility for textiles. However, as of 1 January 2022, three years ahead of the EU directives, a separate collection obligation for textile waste has been introduced.
In December 2021, the Ministry of Ecological Transition held a meeting with various stakeholders representing the textile chain, which was supposed to lead to the formulation of a national EPR regulation. The gas crisis and the raw material crisis then put the work on hold and so it was the organizations themselves who took the initiative.
Thus, a number of consortia were born with the mission to collectively manage textile waste according to EPR obligations: Ecotessili, Retex.green and Cobat TESSILE.
At present, the collection system is still the classic one in which waste is deposited in roadside dumpsters and then entrusted by the municipality to authorized parties through tenders. It is an approach that involves only a few subjects and is also limited in synergies and opportunities, consisting more in the resale of the sorted material through wholesalers or second-hand shops.
What the French experience teaches us, instead, is that the first prerequisite for an effective collection system is its capillarity, and therefore the need to create a network that includes not only municipal structures but also and especially distributors, where consumers often find it easier to dispose of their textiles. There are in fact more than 46,000 collection points in France, including stand-alone points and those located within shops and associations, which is equivalent to approximately one collection point for every 1,440 inhabitants. This has a decisive influence on the country’s collection rate.
So what is hoped for Italy is a greater involvement of existing consortia and the development of some simplifications for distributors, concerning the temporary storage of waste and its possible transportation. It is also crucial that these measures take place at the same time as the EPR system comes into force, to avoid delays having a negative impact on the collection rate, which must instead be raised as soon as possible.
Furthermore, each type of waste has its own peculiarities, which is why the active participation of the sectoral consortia is valuable: to formulate the best textile waste management, textile industry experts are needed.
We await good news and in the meantime encourage you to acquire and spread the habit: do separate collection of textiles, the effectiveness of the system also depends on you.
Want to know how the EU intends to make textiles sustainable?
Here it is, enjoy your reading: Sustainable textiles: the new EU strategy
I sistemi di Responsabilità Estesa del Produttore e il loro ruolo strategico per i produttori
Federico Magalini, Joséphine Courtois, Amba Concheso, Caroline Heinz
Erion and Sofies, July 2021
La Responsabilità Estesa del Produttore (EPR): una riforma per favorire prevenzione e riciclo
Paolo Azzurro, Donato Berardi, Antonio Pergolizzi, Nicolò Valle
REF Ricerche srl, December 2019