Extended producer responsibility policies that work for SMEs in Europe


To support SMEs within the EU and strengthen the Single Market in an omni-channel commerce environment, Ecommerce Europe advocates for an overhaul of the current requirements in the spirit of more harmonization and simplification of EPR rules.

Today, a small and medium sized enterprise intending to sell 1 mobile phone unit in each of the current 28 EU markets could face administrative costs equivalent to 140K Euro, while the actual recycling fees can be as low as 1 Eurocent. To fulfil these administrative requirements, up to 300 reports have to be submitted every year, which equal to almost 40 working days per year to comply with e-waste, batteries and packaging rules.

Small and medium sized enterprises (SMEs) are the backbone of the European economy. Unleashing their full potential is key to preserving jobs, livelihoods and for a swift recovery. Product environment levies, technically known as extended producer responsibility (EPR) rules, place a substantial administrative burden on European SMEs in general and online sellers in specific. Ecommerce Europe has released an awareness raising video to outline the present status on extended producer responsibility legislation in the European Union and advocate for change.

EPR obligations originate from legislation of the 90s and early 00s when e-commerce represented only a marginal sales channel. With the advent of digitalisation and increased popularity of e-commerce, compliance requirements must follow suit and offer a convenient compliance option for merchants wanting to sell online. It is important that funding for recycling schemes is secured to increase collection and recycling of goods at the end of their useful life, while ensuring that companies, particularly SMEs, can continue to sell freely across the EU Single Market without incurring friction when selling cross border.

Enabling SMEs to sell online is crucial, especially as part of the EU’s post-COVID recovery measures. Being one of the EU’s greatest achievements, the EU Single Market has fuelled economic growth and made everyday life of European businesses and consumers easier. Businesses in Europe, including SMEs, are already contributing to the transition to a sustainable economy and Single Market, and the contribution to the financing of collection and recycling is an important part of that contribution. However, every EU Member State has its own unique way to implement EPR obligations for electronic waste, batteries, packaging, as well as several other waste streams. The resulting complexity makes the EPR obligations hard to understand and highly resource intensive to implement for companies. This puts especially SMEs at a disadvantage and makes compliance disproportionately burdensome. As a result, sellers are often not aware of their obligations and if they are, compliance is a challenge, and the contribution to the transition to a sustainable economy is hampered.

The EU Single Market requires a one-stop solution with harmonized EPR obligations across EU Member States, including harmonized reporting requirements (e.g. on eco-modulation) as well as a simplified compliance fee payment procedure and easier product information reporting obligations. These measures would not only ensure free and fair intra-EU trade for all companies but also strengthen the Single Market. The financial sustainability of current EPR systems across Europe would be ensured, and the role of SMEs in the transition to a sustainable economy would be further promoted, working towards supporting the goals laid out by the ambitious European Green Deal and Circular Economy Action Plan.


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Ecommerce Europe
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Website: www.ecommerce-europe.eu  
Twitter: @Ecommerce_EU

Press contact Ecommerce Europe

Juliette Beaulaton
Public Affairs Advisor
Tel: +32 2 502 31 34
Email: juliettebeaulaton@ecommerce-europe.eu