FESI Statement

The FESI statement has been shared with high level EU officials. (list below) and calls the European Commission to simplify, harmonise, and digitalise Extended Producer Responsibility (EPR) across the EU.

As raised previously, currently, companies face highly fragmented and complex EPR obligations across Member States, leading to significant administrative burdens — especially for businesses active in multiple product categories and countries.

The statement strongly supports the Commission’s proposal for a Digital One-Stop Shop (OSS) for EPR, as part of the EU’s Single Market Strategy and Circular Economy Act.

The proposed OSS would:

• Provide centralised information on EU and national EPR schemes.
• Enable single registration, reporting, and payment processes, leveraging AI tools for data consolidation.
• Facilitate communication between producers, national registries, Producer Responsibility Organisations (PROs), and authorities via APIs.

The signatories urge the Commission to:

• Establish a legal basis for the OSS, ensuring neutrality and broad accessibility.
• Support digitalisation of existing and future EPR registries with harmonised requirements.
• Further harmonise key aspects of EPR (data reporting, reporting frequencies, product categorisation, eco-modulation criteria) through EU legislation.

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Signatories include:

1. ‍‍CCIA Europe
2. Ecommerce Europe
3. Eurocommerce
4. EURATEX
5. EUROPEN
6. European Outdoor Group
7. FESI

Recipients :

• Commissioner Roswall + relevant cabinet members
• VP Séjourné + relevant cabinet members
• Hubert GAMBS, Deputy Director-General for Simplification, SMEs, Barrier Removal (GROW.DDG2)
  • Mary Veronica Tovsak Pleterski, Director for Single Market, Enforcement and Barrier Removal (GROW.E)
  • Anna Athanasopoulou, Director for Simplification and networks (GROW.B)
• Mr Aurel CIOBANU-DORDEA, Director for Competitive Circular Economy & Clean Industrial Policy

Ecommerce Europe Study

In parallel of the joint statement, Ecommerce Europe has also issued a study on the administrative burden of EPR schemes in Europe and the call for an EPR One Stop Shop.

Please find below a summary of this study:

Key Findings:

• Severe administrative burden due to fragmentation: EPR obligations vary significantly across Member States and product categories (packaging, WEEE, batteries), creating complex, duplicative compliance processes for producers.

• Main pain points:
  
  • Understanding obligations: fragmented and constantly evolving national rules, often not clearly accessible.
  • Registration: repeated processes per country and product stream, with divergent requirements.
  • Reporting: differing data formats, categorisations, reporting frequencies, thresholds and deadlines.
  • Payments: varying fee structures, invoicing processes and financial guarantee mechanisms across PROs.
• Impact on businesses:
  
  • High resource demands: some companies reported 1,000–4,000 staff hours annually to comply across the EU.
  • SMEs are disproportionately affected; some businesses avoid or withdraw from certain EU markets due to EPR complexity.
  • The burden is expected to increase as more product categories (e.g. textiles) are brought into scope and reporting becomes more granular under the circular economy agenda.

Key Recommendations:

• Establish a EU-wide EPR Digital One-Stop Shop (OSS) to:
  • Provide centralised, multilingual information on EPR obligations across Member States.
  • Enable single-point registration, reporting, and payment processes for all applicable product streams.
  • Use technology (e.g. AI) to prefill data fields and automate repetitive compliance tasks.
• Harmonise key aspects of EPR rules across Member States (definitions, product categorisations, data formats, deadlines, eco-modulation criteria) to maximise OSS effectiveness.
• Recognise that full harmonisation may not be immediately achievable; however, a well-designed OSS would still substantially reduce administrative complexity.

The study underscores FESI’s track record of calling for an urgent need for simplification and digitalisation of EPR compliance at EU level to safeguard competitiveness, reduce costs for businesses (particularly SMEs), and support circular economy goals.

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