“Regulation sets the direction – but implementation is where the work begins.”

Regulatory frameworks in Europe have evolved considerably in recent years. For PROs and recycling organisations, that means the work is shifting from “what should the rules say?” to “how do we make them function in practice?”

Which PPWR-related topics are most relevant to EPRO right now?

• Mike Jefferson: “A lot of activity is currently focused on secondary legislation and implementation. By the end of this year there are deadlines for secondary legislation on topics such as the recycled content methodology and sustainability criteria for recycling technologies. There is also work around equivalence rules for recycled content coming from third countries – often refered to as the ´mirror clause`.
  In parallel, there are other files that matter to members and sit outside the PPWR – such as the end-of-waste criteria for plastics. There are also discussions on issues such as the average loss rate methodology used for calculating recycling rates.

“In the working groups, we turn complexity into something workable.”

When legislation becomes more detailed, interpretation and implementation can look very different from country to country. EPRO’s working groups are where members compare approaches, share operational experience and try to build common understanding.

What are your working groups currently doing – especially the Technical Working Group regarding the PPWR? Can you give examples?

• Mike Jefferson: “The Technical Working Group focuses on technical topics, but those topics are now often closely linked to legislation. There is also significant interaction between the technical and regulatory groups.
  One current example is the recycling rate methodology for chemical recycling. Countries are taking different views on how recycling rates should be calculated in this context. Some are waiting for further Commission guidance. But from a PRO perspective, it is vital to understand how plastics supplied into these technologies can be counted towards recycling targets. In some countries, material supplied to chemical recycling cannot be counted at all; in others it counts, but national methodologies can differ or remain unclear.
  Another area we are starting work on is the recycling of household flexible packaging. As recycling targets rise, flexibles become increasingly important – but they are complex to recycle, and the level of development differs significantly across Europe. Some countries have been collecting and recycling flexibles for decades; others are only at the beginning of the journey. We are therefore preparing a broader survey across Europe to better map the situation.”

“There’s no point collecting if the recycling capacity isn’t there.”

Market and infrastructure realities are currently a key concern across the plastics recycling chain – especially when policy targets ramp up quickly.

Where do you currently see the biggest challenges?

• Mike Jefferson: “One major challenge is the market situation for plastics recyclers. Operating conditions have been difficult, and we have seen a loss of recycling capacity. There is no point collecting and sorting material if the infrastructure to recycle it cannot operate sustainably. EPRO has therefore been active together with other value chain associations in providing input to the European Commission on how the market situation can be improved. We also discuss within EPRO what PROs can do – such as supporting the use of recycled content and using tools like eco-modulation.
  Another challenge is how to achieve gradual improvement over time. PPWR targets are important policy drivers, but the targets typically come with significant jumps every five years. One question is how to ensure more continuous year-on-year development – both in sorting and recycling capacity – so that investment and system development can grow steadily. Discussions around interim targets can be part of that.”

“Better data is essential – and the reporting burden is rising.”

Data, transparency and comparability are increasingly central – both for tracking progress and for implementing compliance requirements.

What trends do you see in data collection and quality – and what does this mean for members?

• Mike Jefferson: “Data availability and granularity vary widely by country. Often, at national level it can be difficult to access data in a granular way – for example by polymer and format. In some countries, data tends to be better, particularly where PROs own and control the material. In others, the granularity is low.
  The PPWR will help because it introduces more detailed reporting categories. For example, flexible packaging will become a separate reporting category, whereas today many countries only report “plastic” overall. However, even with the PPWR, there may still be limitations – for example, categories may not always be split between commercial and industrial versus household streams. Better data will remain essential to inform investment decisions. 
  From a PRO perspective, reporting will become more complex. Beyond the main categories, PROs may also need to manage national reporting requirements, data related to the Single-Use Plastics Directive, and more granular reporting linked to eco-modulation schemes.”

How are declarations of conformity affecting the sector?

• Mike Jefferson: “Declarations of conformity are an important aspect of PPWR. Industry is starting to look at what this means and put measures in place in supply chains – it still feels early-stage for many. Industry are looking for continued guidance and support on what they need to do to be compliant, and what responsibilities they have. PRO obviously have an important role here.
  That links to definitions as well. There’s been Commission guidance, but there are still uncertainties – for example definitions of producers and manufacturers. And that affects responsibilities and who has to report what.” 

Collaboration in the network: “Knowledge is created in exchange – not in isolation.”

With complexity rising, Mike Jefferson argues that collaboration is not a “nice to have”, but an operational necessity.

How important is collaboration within EPRO and in general today?

• Mike Jefferson: “The need for collaboration and networking is becoming more important, not less. The complexity is increasing – both in the policy objectives and in legislation itself. New legislation needs interpreting and then implementing. Being able to sit together – face-to-face or virtually – and exchange interpretations and experiences helps members understand what is happening and how implementation can be done efficiently and effectively.
  It also works the other way: by bringing many countries together, EPRO can consolidate real-world experience, identify consistent themes and challenges, and communicate those back to legislators. We try, as much as possible, to go to legislators with solutions – not just problems.”

RIGK & EPRO: “Active participation makes the difference.”

RIGK’s 20-year involvement in EPRO is closely linked to the practical experience it brings – especially in agricultural plastics, where approaches differ widely across Europe.

How do you view RIGK’s role within EPRO?

• Mike Jefferson: “RIGK’s role within EPRO is very important – 20 years of involvement says a lot. RIGK brings extensive experience, and individuals within the organisation bring deep industry knowledge. RIGK is active in commercial and industrial packaging and in agricultural plastics, and with Jan Bauer chairing the Agricultural Working Group, RIGK plays a key role.
  Agricultural plastics are an area where international exchange is particularly valuable. While there are not yet mandatory EPR requirements across Europe, the discussion is ongoing. Several countries – including Germany, France and Ireland – have a long history of collecting agricultural plastics, and therefore strong experience in operational setup, financial models, governance and value chain involvement.
  This will be increasingly important as agricultural plastics collection systems expand across Europe, especially in countries where schemes are only now being established – for example in parts of Scandinavia.”