Extended Producer Responsibility: What We Know and What We Don’t
Extended Producer Responsibility (EPR) has emerged as one of the most discussed policy tools aimed at driving more circular outcomes for various consumer goods. EPR for some materials – like car batteries – electronics, and consumer items – like mattresses – is relatively mature. However, EPR for packaging is new and is the primary focus of most current EPR legislation being implemented or under consideration.
Since the early 2000s, the adoption of EPR policies has grown rapidly worldwide. More than 70% of the 384 global EPR policies identified by the Organisation for Economic Co-operation and Development (OECD) researchers were enacted after 2001, with nearly 400 now in force. Europe and Canada lead in implementation, while the United States remains fragmented, with most EPR legislation enacted at the state level rather than federally.
In recent years, states such as California, Oregon, Maine, and Colorado have introduced packaging EPR laws, following the lead of long-standing product-specific programs like PaintCare and the Mattress Recycling Council. Packaging, electronics, batteries, and paint are among the most common products targeted by EPR. While the specific materials differ across countries, the overarching attraction of the EPR concept is relatively straightforward: to shift the responsibility for end-of-life product management away from consumers and municipalities and back onto producers, the entities that are viewed as best positioned to influence product design, packaging choices, and re-use of recovered materials. If successful, the outcomes of EPR are to: reduce environmental externalities, relieve municipalities of financial burden, and incentivize sustainable product design through design-for-environment.
EPR policies use several mechanisms to achieve these aims: take-back requirements, market-based instruments like deposit-refund systems or material taxes, performance standards such as minimum recycled content, and mandatory reporting to improve transparency and consumer awareness. Most programs operate through Producer Responsibility Organizations (PROs), third-party entities that manage compliance, collection, and fee structures on behalf of producers. These fees are often modulated based on material type or recyclability, a practice known as eco-modulation.
For example, producers using easily recyclable materials may pay lower fees than those using difficult or composite materials. In theory, this fee structure is meant to reward better design decisions and drive innovation toward circularity. The level of producer versus municipal responsibility varies. Some systems, like British Columbia’s packaging EPR program, assign full financial and operational responsibility to producers, while others share costs or delegate operations to local governments. This diversity reflects differing policy philosophies, infrastructure maturity, and local economic conditions across North America.
Despite the growth and implementation of EPR policy and its success for specific hard to recover materials, the efficacy of packaging EPR remains unproven. To better understand this, the Environmental Research & Education Foundation (EREF) conducted a literature review of EPR, representing one of the most comprehensive syntheses to date of what is known in an effort to better understand how well these policies work.
The review found a significant imbalance between policy proliferation and data on outcomes. Of the studies examined globally, fewer than 30 directly evaluated EPR performance, and only about 7% focused on quantitative effectiveness metrics. Most research to date describes implementation processes rather than performance results. When data are available, the evidence suggests EPR may improve recovery rates, but with caveats. In Belgium and Germany, packaging recycling rates more than doubled following EPR implementation. In British Columbia, packaging recovery rates increased from around 50 percent to over 80 percent between 2014 and 2021.
However, direct attribution to EPR remains uncertain because of varying baselines, inconsistent definitions, and overlapping policy interventions. A particularly illustrative example is the Product Stewardship Institute’s comparison of Canadian provinces. Each used a different formula to define recovery rate, some dividing recycled tonnes by generated tonnes, others by market supply or collected tonnes, making cross-province benchmarking nearly impossible. Such inconsistencies limit both transparency and policy learning.
The largest barrier to understanding EPR’s real-world impact is the lack of consistent, publicly available data. PROs often hold detailed operational and financial data, but much of it is not publicly reported. The result is a persistent disconnect between projected and verified outcomes. Without standardized metrics or transparent reporting, policymakers cannot accurately determine whether EPR systems reduce waste, improve recycling quality, or create cost efficiencies. This issue extends beyond measurement; it influences policymaking itself. Billions of dollars in producer fees are being collected globally under EPR frameworks, but the absence of verified data means that it is still unclear whether EPR outperforms traditional recycling policies or programs. The literature review suggests this information gap risks unintended consequences such as higher costs or limited progress toward better product design.
Interviews with leading EPR researchers highlight a consensus that EPR is a valuable policy tool but not a panacea. Experts emphasize that its success depends on localized strategies, adequate infrastructure, and adaptive policymaking that responds to market conditions and emerging technologies. They recommend regionally tailored approaches, for instance, focusing on aluminum and paper first in areas with limited infrastructure, while more advanced systems might tackle complex materials like multi-layer plastics. Moving forward, this evaluation identifies a clear research need in leveraging data held by PROs to develop standardized performance metrics and cross-jurisdictional analyses. Transparent, data-driven evaluations would allow policymakers and producers alike to understand where EPR is achieving its goals and where it is falling short.
This review highlights EPR’s imperfections as a policy instrument but also indicates its potential to align economic incentives with environmental outcomes could be significant under some situations, yet its impact cannot be fully understood without better data, harmonized definitions, and transparent reporting. The review underscores both the momentum behind EPR and the need for stronger analytical foundations to better understand its effectiveness.
