EPR Around the World

EPR (Extended Producer Responsibility) is an environmental policy approach that holds producers responsible for the entire lifecycle of their products and packaging, particularly for their end-of-life disposal.

The aim is to encourage more sustainable product design, increase recycling rates, and reduce waste. Here, we provide a current overview of EPR and its implementation worldwide.

Quick links:

• United Kingdom
• European Union
• United States
• Canada
• South Africa
• Australia
• New Zealand
• Global summary

Under an Extended Producer Responsibility scheme, producers (manufacturers, importers, brand owners, and retailers) are legally required to report their packaging waste and pay a fee based on the recyclability of the waste packaging they place on the market.

This responsibility is typically met through:

• Financial contributions: Paying fees to government or third-party recycling and waste management organisations.
• Take-back schemes: Collecting used products and materials for recycling or disposal.
• Product design improvements: Making products and packaging easier to recycle, repair, or reuse.

Significant regulatory changes have been implemented or are in progress across many key global markets, including the United Kingdom, European Union, North America, South Africa, Australia, and New Zealand.

UNITED KINGDOM’S EPR SCHEME

The UK's EPR scheme is now operational and currently undergoing various changes. For example, as reported in our Wrap-Up industry newsletter, the Scheme Administrator and DEFRA have published the final Recyclability Assessment Methodology (RAM) for the Extended Producer Responsibility for Packaging (pEPR) programme.

All packaging classified as "household waste" and introduced to the market by liable producers in 2025 will be evaluated using the RAM methodology that applies red, amber, or green ratings to influence disposal charges.

The modulation of fees will depend on the material category - such as plastic, paper, or glass - alongside the assigned colour-coded categories for each type based on its assessed recyclability.

From 2026, packaging rated green, such as fully recyclable plastic bottles or uncoated paper, will incur lower fees than amber-rated mixed materials or red-rated non-recyclable composites.

The scheme administrator "PackUK" was formally launched in January 2025. PackUK will set pEPR's fees, raise these fees from obligated producers and make packaging waste disposal payments to local authorities in return for the delivery of efficient and effective collection and recycling services.

UK STAGES

Current EPR stages in the UK are as follows:

• From January 1, 2025, large producers supplying household packaging must assess recyclability and prepare to submit reports.
• Large producers (annual turnover exceeding £2 million and handling more than 50 tonnes of packaging) must report packaging data biannually.
• Modulated fees (eco-modulation) will be introduced in 2026 using the RAM methodology.

The UK government estimates that producers' costs under the EPR scheme will be around £2.7 billion in the first full year of implementation.

UPDATE: Defra, in response to retailer concens, has promised a revised version of the RAM traffic light system.

EU STANDARDISATION

Producers in the European Union are expected to take greater responsibility under EPR regulations, as they are increasingly required to manage the entire lifecycle of their products, particularly concerning waste management at the end-of-life stage.

The Packaging and Packaging Waste Regulation (PPWR), which standardised EPR across the EU, was published on January 22 and will take full effect by August 12, 2026.

Unlike the previous "EU Packaging Directive", the new regulation is legally binding for all 27 EU member states, ensuring uniform implementation across the region.

Initiatives include recycling, the adoption of reusable packaging, and increased use of recycled materials, as well as achieving the key targets for:

• All packaging must be recyclable by 2030.
• Packaging reduction to be 5% by 2030, 10% by 2035, and 15% by 2040 (compared to 2018).

While PPWR comes into force during February 2025, the official start of the regulation's validity is expected in the summer of 2026.

From February 2029, PPWR will ban single-use plastic packaging for pre-packed fruits and vegetables weighing less than 1.5 kg and food and beverages consumed within hotels, bars, and restaurants.

STATE-LED APPROACH IN US

Unlike the UK and EU, the United States follows a fragmented, state-led approach to EPR. No federal EPR law exists, meaning policies vary by state and product category.

However, multiple US states have passed EPR for packaging policies and related legislation, and the ramp-up for those laws is ongoing. For example:

• Maine and Oregon were the first states to pass EPR laws for packaging in 2021, requiring producers to cover the costs of municipal recycling programmes.
• Minnesota and Washington are in the active implementation stages, and new EPR laws will be enacted in Oregon and Colorado shortly.
• California's EPR model includes eco-modulated fees prioritising packaging recyclability, and producers must report data to the Circular Action Alliance (CAA) for California and Colorado by August 31.

CANADA IS VARIABLE

Canada’s EPR system primarily operates at the provincial level, meaning regulations and enforcement vary by region. Unlike in the EU or UK, where EPR is standardised nationally, Canada does not have a federal EPR framework governing all provinces.

However, some national standards exist, such as the Canada-wide Action Plan for Extended Producer Responsibility, developed by the Canadian Council of Ministers of the Environment (CCME).

It aims for a consistent approach across provinces.

British Columbia is currently adjusting its EPR framework and has outlined its priorities in a five-year action plan.

Quebec has a well-established producer-led EPR programme, while Alberta introduced a new framework last year, and the Yukon Territory's EPR Regulation requires programme plans by the end of this year.

MANDATORY IN SOUTH AFRICA

Since 2021, South African producers must register with the Department of Forestry, Fisheries and Environment (DFFE) and ensure all identified products are covered by an Extended Producer Responsibility (EPR) scheme.

Obligated producers can join an existing Producer Responsibility Organisation (PRO), develop an independent EPR scheme, or form a new PRO.

Some of the key South African milestones include:

• November 5, 2020: The legal framework for EPR was established by publishing the regulations under the National Environmental Management: Waste Act, 2008.
• May 5, 2021: EPR regulations came into effect, with a six-month grace period for compliance.
• November 5, 2021: Deadline for producers to register with the South African Waste Information Centre (SAWIC) and submit EPR plans or join a PRO.
• January 1, 2022: The official start of EPR in South Africa, 2022 marked year 1 of South Africa’s EPR legislation, EPR fees are payable as at 1 Jan 2022.   

AUSTRALIA IS REFORMING

Australia's packaging EPR framework is evolving, but the Australian Packaging Covenant Organisation (APCO) currently manages voluntary and co-regulatory schemes.

The National Packaging Targets aim for “100% of packaging to be reusable, recyclable, or compostable by 2025", but that is not expected to be met.

APCO's “2030 Strategy” introduces eco-modulated fees, meaning packaging that is difficult to recycle will attract higher compliance costs, while more sustainable materials will be incentivised.

COMPULSORY IN NEW ZEALAND

New Zealand has mandated EPR for plastic packaging, making participation compulsory, unlike voluntary or co-regulatory systems in some regions.

Additionally, its government planned to phase out all difficult-to-recycle plastic containers and packaging by 2025. However, this deadline has been postponed due to implementation challenges.

GLOBAL ACTIVITY

Here is a summary of the EPR status of various countries:

• United Kingdom: All household packaging must be assessed for recyclability from 2025, with modulated fees from 2026.
• European Union: All packaging must be recyclable by 2030, with packaging waste to be reduced by 5% by 2030, 10% by 2035, and 15% by 2040.
• United States: No national target. EPR is state-led, with California's programme requiring producers to report data by August 31 2025.
• Canada: No national target. British Columbia’s EPR expansion includes adding new materials and a five-year roadmap.
• Australia: 2025 targets are not expected to be met, but the country's EPR framework is evolving.
• New Zealand: Mandatory EPR for plastic packaging, but postponed an initial goal of phasing out problematic plastics by 2025.
• South Africa: EPR regulations for packaging and electronics were implemented in May 2021.
• Japan: Mandated producer recycling targets are set under the Japan Containers and Packaging Recycling Association.
• India: EPR for plastic packaging is under the 2016 Plastic Waste Management Rules.
• Chile: Specific packaging waste recovery targets for various materials.

As more countries step up their fight against waste, EPR is becoming a significant tool influencing everything from product and packaging design to supply chain decisions.

Producers that embrace innovation, improve recyclability, and engage in circular economy initiatives will comply with regulations and future-proof their businesses in an increasingly eco-conscious world.

EPR AROUND THE WORLD TABLE

NAVIGATING EPR

The goal of EPR legislation across the globe is the same: to reduce the amount of non-recyclable packaging in our stores and in the consumer’s waste bins. To mitigate the financial consequences for companies who will be responsible for packaging there are a few actions you can take, such as:

• Using less packaging for your product
• Downgauging or lightening packaging where applicable
• Switching to recyclable packaging materials

All of these actions can impact the EPR fees that your company will be faced with and potentially can save you money while reducing your waste.

KM Packaging is supporting our customers through this EPR journey. If you’re unsure about how to proceed with your flexible packaging under the EPR regulations, get in touch with team at KM to discuss your options. Contact us at [email protected]

You can keep up with EPR and other industry matters through our Wrap-up Newsletter and Knowledge section on our website.