European Recycling Platform (ERP), a Landbell Group company, has commented on the recent draft guidance on Extended Producer Responsibility produced by the environmental consultancy, Eunomia. With more than 20 years’ experience implementing extended producer responsibility schemes across Europe, ERP fully supports the EU’s efforts to achieve greater harmonization. The company has produced this comments paper to share some of its operational experience and expertise and to highlight certain aspects that it feels are not sufficiently taken into account in the draft guidance, thereby challenging some of the conclusions and implicit recommendations. ERP has also produced this paper to offer suggestions as to how the EU can better achieve its goals.
The comments paper covers a wide range of topics, offering suggestions on the scope of costs covered for reinforcement, how to distribute funds to make up for geographical differences, and how to ensure efficient service delivery. ERP also comments on fee modulation, equal treatment, and tackling free-riding.