Extended Producer Responsibility (EPR) plays a pivotal role in funding, coordinating and facilitating the recycling of consumer flexible and all packaging. CEFLEX and its stakeholders have been working to ensure EPR mechanisms are able to drive cost-effective collection and recycling of flexible packaging to make it circular, sustainable and economically viable. This webinar from April 2020 by CEFLEX and EXPRA - Extended Producer Responsibility Alliance outlines some of the key issues and mechanisms.

1. www.CEFLEX.eu1
Alec Walker-Love, CEFLEX Workstream Consultant & Webinar host
Joachim Quoden, Managing Director, EXPRA
Graham Houlder, CEFLEX Project Coordinator
EPR – A key factor in realising the circular
economy for flexible packaging.
16 April 2020 – 11:00-12:30 CET Brussels - Zoom

2. www.CEFLEX.eu2
Welcome
This webinar is in 4 parts:
1. Building understanding of how EPR for packaging materials works in Europe (GH - CEFLEX)
2. A critical look at Europe’s EPR systems and the required changes they need to embrace (JQ –
EXPRA)
3. Why EPR is a key factor in realizing the circular economy for (flexible) packaging in Europe (GH –
CEFLEX)
4. Questions from participants

3. www.CEFLEX.eu3
Introduction to EPR and it’s relevance for
the CEFLEX project.
Graham Houlder – Project Coordinator, CEFLEX
NB: All data is for illustrative purposes only!
Not to be used for commercial comparisons.

4. www.CEFLEX.eu4
EPR
• EPR = Extended Producer Responsibility (EPR)
• Created by the European Commission in the 1990’s when the first
Packaging and Packaging Waste Directive became legislation.
• Widely implemented globally (although no two EPR systems are the
same!)

5. PACKAGING EXTENDED PRODUCER RESPONSIBILITY (EPR)
Packaging EPR in 2000
5
Packaging EPR in 2020
Source: Lorax EPI
www.loraxcompliance.com | info@loraxcompliance.com | www.enviro-pac.com

6. www.CEFLEX.eu6
Purpose
• EPR systems help implement, manage and fund the collection and
sorting of product and packaging materials when they become “waste”
• In most instances the EPR system is designed to:
• Meet RECYCLING TARGETS for packaging and other materials
• Enable Brand Owners and Retailers to fulfill their legal responsibility to
manage the “waste stage of a product’s lifecycle”

7. www.CEFLEX.eu7
How does EPR work?
• Companies placing packaging (Producers) on to
the market pay a contribution per pack to the
“EPR System” that pays for it to be collected
sorted and recycled. The EPR contribution is:
• Weight based and material specific
• Set by the EPR system in the country.
• An integrated part of the product cost
EPR
Indicative Product
Cost Make-up

8. www.CEFLEX.eu9
The Money Flow in an EPR System
EPR
EPR
EPR
EPR
EPR
EPR
Company A
EPR
EPR
EPR
EPR
EPR
EPR
Company B
EPR
EPR
EPR
EPR
EPR
EPR
Company C
€
€
€
€
€
€
€
€
€
EPR
€
€
€
€€€
€€€
Recycler
Recycler
Recycler
-/+ €
-/+ €
-/+ €
Note: Recycled plastic
competes directly with virgin
€
€
€
NB: if any part of this process is not profitable, the whole chain stops working!

9. www.CEFLEX.eu10
EPR: How does it work?
0
200
400
600
800
1000
1200
1400
1600
Mech Recycling Mech Recycling
with EPR
Monomer
Recycling
Feedstock
Recycling
(Pyrolysis
Gasification Virgin Polymer Waste to Energy
High Low Median
Example indicative of Plastics Recycling Today
1. Mechanical recycling:
• Separate Collection and Sorting of packaging ~700-800
€/ton
• Mechanical recycling of flexible packaging ~ 500 €/ton
• Total cost ~1300 €/ton
• Virgin plastic cost ~800-1200 €/ton
Challenge:
• How to make recycled plastic economically viable relative to
virgin plastics
NB: All data is for illustrative purposes only! Not to be used for commercial comparisons.

10. www.CEFLEX.eu11
EPR: How does it work?
0
200
400
600
800
1000
1200
1400
1600
Mech Recycling Mech Recycling
withEPR
Monomer
Recycling
Feedstock
Recycling
(Pyrolysis
Gasification VirginPolymer Waste to
Energy
High Low Median
Solution:
• Producers subsidise the cost of collection and sorting =
EPR
Example indicative of Plastics Recycling Today
• EPR contribution ~700-800 €/ton
• Net cost price ~ 500€/ton
• Sales price ~600-700 €/ton
• Margin >100 €/ton
• Enables some packaging materials to be “circular”
• But rFP materials sales price 250 – 450 €/ton
• Conclusion: It is often not economically viable to
collect, sort and recycle FP
NB: All data is for illustrative purposes only! Not to be used for commercial comparisons.
EPR fees contributes to
Collection and Sorting
costs
rPlastic
Margin

11. www.CEFLEX.eu12
What does EPR cost?
• Varies greatly by country depending on 1) the national recycling targets, 2) the share of
costs covered (full costs in Germany, Belgium etc versus part of the costs e.g. 10% in UK)
and 3) the scope of EPR (in BE and NL EPR pays for anti litter campaigns, > 1.5€ pppa.)
• Increasing the recycling targets (& measurement point) = increasing EPR contributions.
• The reported costs per capita (~2017) were:
• The Netherlands: 8€ p.p.p.a.
• France: 10€ p.p.p.a.
• Germany: ~12€ p.p.p.a.
Note: To meet the new recycling targets, EPR costs are expected to increase significantly!

12. www.CEFLEX.eu13
What does EPR cost?
• Assuming each consumer uses 20-30 packs per day the net average cost
per pack can be calculated:
• The Netherlands: 8€ p.p.p.a. = 0.09 cents (€)
• France: 10€ p.p.p.a. = 0.11cents (€)
• Germany: ~12€ p.p.p.a. = 0.13 cents (€)
• Issue: In many countries flexible packaging pays (significant) EPR “fees” but
is not (yet) collected as the legal targets could be met without FP.
• Challenge: to ensure the actual cost of collecting, sorting and recycling FP is
included in the FP EPR fees.

13. www.CEFLEX.eu14
EPR: How does it work for FP?
0
200
400
600
800
1000
1200
1400
1600
Mech Recycling Mech Recycling
withEPR
Monomer
Recycling
Feedstock
Recycling
(Pyrolysis
Gasification VirginPolymer Waste to
Energy
High Low Median
Challenges for post-consumer flexible
packaging:
• Very little (~700 ktpa) is actually
recycled today as most rFP is not
competitive v Virgin
• Consequently, available end markets
and capability to supply them are limited!
• Mainly the easy to recycle flexible packaging
(LDPE > A4) where a viable business case is
possible
NB: All data is for illustrative purposes only! Not to be used for commercial comparisons.
EPR contribution allows
to easy to recycle >A4
FP to be recycled
economically
= rPlastic
Margin ~ <0€

14. www.CEFLEX.eu15
EPR: How does it work?
0
200
400
600
800
1000
1200
1400
1600
Mech Recycling Mech Recycling
withEPR
Monomer
Recycling
Feedstock
Recycling
(Pyrolysis
Gasification VirginPolymer Waste to
Energy
High Low Median
CEFLEX Vision to realise the CE4FP
1. “Design” EPR to cover cost of
delivering recycled plastic materials so
that collectors, sorters, recyclers
businesses are economically viable.
2. Need to meet identified End Markets
quality, quantities and still be
competitive v Virgin
NB: All data is for illustrative purposes only! Not to be used for commercial comparisons.
EPR contribution
rFP Margins
big enough to be
profitable

15. www.CEFLEX.eu16
EPR and Legislation
* Packaging taxes tend to disappear into the State coffers at best only being partially used to improve recycling infrastructure.
• EPR & related legislation is VIP as it:
• Determines what materials are made available for recycling. Also what
quantities and qualities.
• Creates a “level playing field” for all companies placing packaging onto
the market.
• Provides the “guarantees” needed for long term investment in the
required infrastructure.
• Makes the collection, sorting, recycling steps economically viable.
• Without EPR (or packaging taxes*) it would likely not be economically viable to collect
and sort most packaging (even glass, paper and metals) in Europe.

16. The importance of Extended Producer
Responsibility for CEFLEX to deliver the CE4FP
Joachim QUODEN
Managing Director of EXPRA
CEFLEX EPR Webinar
16 April 2020 | Zoom

17. EXPRAin a nutshell
26MEMBERS
industry-owned,non-profit
25
of experience and
expertise in the
waste management
field
HAVE
YEARS
over
200
with packaging
collection, sorting
and recycling
infrastructure
PROVIDE
MILLION
PEOPLE
over
20of packaging every year
ENSURE RECYCLING AND RECOVERY
MILLION TONNES
ofover
7 years existence

18. Extended Producer Responsibility
• Extended Producer Responsibility (EPR) is a resource management tool whereby
producers have to take over an individual “producer’s” responsibility for the end of
life management of their used products/packaging. This can include financial and/or
operational responsibility for the collection, sorting and treating these
products/packaging for their recycling and recovery.
• This individual responsibility can be partly transferred to a collective entity, the so
called “Producer Responsibility Organisation” (PRO)
• This PRO should fulfil the obligations of their members in the most efficient and
effective way, so usually fulfil inter alia the recycling targets set by the national
government or on top, additional targets set by the owners of the PRO.
• The needed (usually external) costs shall be internalized into the product price
• Higher costs for non-recyclable or difficult to recycle packaging should motivate
industry to eco-design their packaging

19. EPR is an efficient tool by which producers deliver their responsibility
for the life cycle management of their products
• Design of the packaging
• Choice of materials
• Manufacture for easy emptying / repair / dismantling /
separation
• Usage by the consumer
• End of life management
• Uptake of recycled content
Extended Producer Responsibility

20. EPR’s role in a circular economy
Contract agreements
Financed by
fees
EPR Producer
Responsibility
Organisation
Retail trade
Local Authority’s Waste
Management Company
Collection & Sorting
Recycling/
recovery
Material for new products
Packaging
manufacturer
Filler/bottler
Packed
product
Consumer
New products
Sorting
Operational
ANDfinancial
responsibility

21. EPR System / PRO
• The design of each national EPR System and each PRO is
determined by
• The EU legislation (WFD / PPWD / SUP)
• The respective national implementation
• Obliged industry in a respective country if and when owning the
PRO or the 3rd Parties owning the PRO (investors, waste
management companies, recyclers, e.t.c.)
• Local authorities who usually decide about the concrete collection (and
sorting) system in their district

22. Implementation of the Packaging Directive
3 countries without any
compliance scheme =>
Taxes
Denmark, Hungary, Croatia
Trading of certificates
UK, (Poland)
30 with Producer Responsibility
Austria, Belgium, France, Spain, Germany, Ireland, Cyprus, Luxembourg, Portugal,
Sweden, Greece, Latvia, Malta, Lithuania, Czech Republic, Slovak Republic, Italy,
Slovenia, Estonia, Romania, Bulgaria, Turkey, Norway, Finland, Serbia, Israel,
Netherlands, Poland, Macedonia, Bosnia I Herzegovina
36
European
Countries
Tax versus EPR
continuous discussion
Ukraine, Russia ?
1 country with Fund
Scheme run by industry
Iceland

23. Plastic Recycling Quotas in 2017
old measurement point / no check of reporting
0
10
20
30
40
50
60
70
80
90
100

24. A good performing MS: 1997 – 2017
0
10
20
30
40
50
60
70
80
90
100
199719981999200020012002200320042005200620072008200920102011201220132014201520162017
Recovery overall Recycling overall Glass recycling
Metal recycling Paper recycling Plastic recycling

25. EPR - several ways of implementation
EPR System in hands
of obliged industry
(BE, ES, IT, NL, NO, CZ,
FR, IE, LU)
Competing PROs
(DE, AT, PT, LT, SV, SK,
PL, RO, BG, ….)
‘Tradable Credits’
Model with several
traders
(UK)
Several PRO‘s sharing
infrastructure
(DE, AT)
PROs acting in
different areas
(BG)
PROs have
established parallel
infrastructure
(EE)
Operational
responsibility fully
with local authorities
(FR, NL, CZ)
Collection and
sorting with local
authorities
(BE, ES, IT)
EPR system in parallel
to a deposit system
(DE, NO, SE, FI, EE, LT)
One comprehensive
system for all
(household)
packaging
(e.g. BE, FR, ES, IT)
No EPR for
commercial
packaging
(DE, FR, ES)
Same rules for all
packaging
(e.g. IT, CZ, SK, RO)
Dual system
approach
(e.g. DE, AT, BE, SE)
Shared cost
approach
(e.g. IT, ES, FR)
Incentive cost
approach
(UK)
Obliged entity are
fillers (and importers)
(e.g. DE, AT, SE)
Obliged entity is the
packaging producer
(and the importers)
(IT)
Obliged entity is the
whole value chain by
percentages
(UK)
Special EPR system(s)
for commercial
packaging
(e.g. BE, AT)

26. Waste Framework Directive (2018)
Article 8a
Sets out general, minimum requirements for EPR with regards to:
• Roles and responsibilities
• Target compliance
• Reporting
• Equal treatment of producers
• Information to waste holders
targeted by EPR schemes &
Member States
• Transparency
• Cost coverage
• Eco-modulation
• Efficient & necessary costs
• Monitoring and enforcement
• Independent Oversight in case of
competition
• EU & National Dialogue platforms

27. Challenges & Opportunities
§ Higher recycling targets (70% for all packaging, 55% for plastic
packaging)
§ Plus a new measurement point in front of the extruder (reduction of
the current performance by by 5% to 30%)
§ Packaging put on the market will be checked by the Commission
§ Full coverage of the „necessary“ net costs for collection, sorting,
treatment, communication plus cost coverage for cleaning up litter
§ Additional measures for packaging under SUP
§ Uptake of 10 Mio t of recyclates

28. Consequences for PRO’s and companies in short
• Extended scope, targets and cost coverage will lead to much higher costs for obliged
industry respective the whole value chain
• Countries with a performance close to the new targets have a cost of 20€ per person/annum
• Additional increase because of the new measurement point
• Additional costs for litter clean up, depending on the national decision on scope and share
• This might lead to a likely cost of 40€ per person per annum
• And these costs will not be distributed any more by a flat fee for all plastics but „eco-
modulated“ taking into account „recyclability“ (in the new sense)

29. Can we achieve and deliver?
• We need now very quickly reasonable guidelines and acts from the European Commission: Ask
your EU associations to join forces with EPR (for example with EXPRA)
• We need the implementation of all new directives into national law as soon as possible using best
practices and avoiding new experiments -> National industry has to join forces immediately
and lobby for the best legislation possible (pass the message to your local companies and
their local associations)
• We need an immediate enforcement of the new rules
• We need concerted action of industry in each country together with their EPR system to upgrade
their infrastructure (Stop complying with the cheapest but with the best for your goals)
• EPR systems and industry have to work on design for recycling to make as much packaging
really recyclable to reduce costs and to avoid bans (Essential Requirements!)
• The value chain of each packaging type has to work on solutions for each type of their packaging
to ensure enough uptake (Best practice: CEFLEX!)
• We all have to work with our inhabitants to motivate them to do the right thing!

30. PARTNERSHIP IS KEY TO SUCCESS

31. THANK YOU!

32. Contact
EXPRA aisbl
2 Avenue des Olympiades
1140 Brussels – Evere
Belgium

33. www.CEFLEX.eu41
Why EPR is important for CEFLEX and
delivering the CE4FP
NB: All data is for illustrative purposes only!
Not to be used for commercial comparisons.

34. www.CEFLEX.eu42
Challenges to delivering the CE4FP
1. All flexible Packaging must be collected and made available for
recycling.
2. It must be economically viable for collectors, sorters & recyclers to
operate their businesses. It needs to be possible to make a profit!
3. The “Risk/Return” equation needs to be sufficiently interesting to attract
investment in the needed infrastructure/capacity.
4. Recycled plastic (from flexible packaging) needs to be competitive
relative to the moving free market price of virgin resin (for a comparable
quality)
EPR

35. www.CEFLEX.eu43
Challenges to delivering the CE4FP
1. All flexible Packaging must be collected and made available for
recycling.
2. It must be economically viable for collectors, sorters & recyclers to
operate their businesses. It needs to be possible to make a profit!
3. The “Risk/Return” equation needs to be sufficiently interesting to attract
investment in the needed infrastructure/capacity.
4. Recycled plastic (from flexible packaging) needs to be competitive
relative to the moving free market price of virgin resin (for a comparable
quality)
EPR

36. www.CEFLEX.eu44
Influencing EPR Developments
• Need the aligned support of the Producers (brand owners and retailers)
• CEFLEX has 19 brand owners/retailers:
• Alignment of their perspectives of the minimum requirements for what EPR systems
must deliver will provide very important potential leverage with all the European EPR
systems to implement the changes needed.
• Barilla
• Coca Cola
• Danone
• Ebro Foods
• Ferrero
• Lotus Bakeries
• Mondelez
• Nestlé
• P&G
• Pepsico
• Pladis
• Royal Canin (Mars)
• Unilever
Retailers:
• Marks and Spencers
• Hill’s Pet Nutrition (Colgate)
• Hipp
• JDE
• Lavazza
• L’Oreal

37. www.CEFLEX.eu45
An EPR Vision for the Circular Economy
• We need an agreed and harmonized Vision for EPR in Europe that is
consistent with the needs of a circular economy for flexible packaging.
• This “Vision”:
• Is based on the changes/actions needed to deliver the 4 key Challenges
• Needs the full support of the CEFLEX brand owner / retailer Stakeholders
and to be endorsed at Board level.
• Needs to be consistent with developing the circular economy for all
packaging materials.

38. www.CEFLEX.eu46
Developing this EPR Vision
Next steps:
• Virtual meeting of CEFLEX Brand owner/Retailer VCM: 4th May 2020
• Discussions to agree on:
• What this Vision needs to address.
• To support fully funding collection, sorting, recycling of all packaging
• The potential scale and cost benefits from driving more harmonization of EPR
within the EEA
• What is needed to implement this Vision in all countries in the EEA
• Implications of not doing it!

39. www.CEFLEX.eu48
Audience Questions on EPR
Summary of the 4 Key Challenges needing to be addressed (at least in part) by
EPR.
1. All flexible Packaging must be collected and made available for recycling.
2. It must be economically viable for collectors, sorters & recyclers to operate their
businesses. It needs to be possible to make a profit!
3. The “Risk/Return” equation needs to be sufficiently interesting to attract
investment in the needed infrastructure/capacity.
4. Recycled plastic (from flexible packaging) needs to be competitive relative to the
moving free market price of virgin resin (for a comparable quality)

40. www.CEFLEX.eu49 www.ceflex.eu49 www.CEFLEX.eu49
Thank you for joining this Webinar
Presentations and the recording of this webinar will be made
available after the meeting on the CEFLEX Stakeholder space.
The link will be sent by email to all registered participants.