German take-back system GRS says there is an urgent need to reform the implementation of extended producer responsibility (EPR) in the European Union. In a recently published position paper, the compliance scheme operator warns that excessive bureaucracy, fragmented rules and inefficient administrative processes are hindering both the work of the waste management sector and progress towards a circular economy. Instead of supporting take-back systems, recycling innovation or consumer engagement, the present legal framework is diverting resources from these more impactful sustainability efforts.
The battery take-back system operator identifies the lack of harmonisation among member states as the central weakness of today’s EPR regimes. Divergent national rules on registration, reporting and enforcement create legal uncertainty, particularly for companies operating across national borders. In addition, interpretations of definitions differ and procedures are inconsistent. Producers also face redundant reporting obligations, often having to submit the same data in different formats to multiple authorities. Lengthy and opaque procedures for registrations and approvals further delay market access and slow down innovation.
Against this background, GRS Service GmbH is calling for clearer, more efficient and more consistent standards across the EU. The company advocates harmonised and unambiguous provisions that set out uniform definitions, deadlines and obligations across all member states. It also calls for a clear determination of what constitutes a producer and which product categories fall under EPR. Single digital access points for companies active in multiple countries could help streamline processes.
Administrative procedures should also be significantly simplified. GRS proposes clear deadlines for registration and permit decisions, along with standardised, machine-readable templates for reporting. Electronic signatures and digital documentation could replace paper-based processes. The company also argues for more efficient and transparent oversight. Mutual recognition of compliance between member states could reduce duplicate audits and registrations, while greater transparency from authorities would reduce legal uncertainty.
Finally, GRS argues for "smarter rulemaking" and "fair implementation". Proposed rules should be subject to a "real-world test" to ensure that requirements are proportionate to company size. Over-regulation must be avoided and costs fairly distributed, especially with regard to small and medium-sized enterprises and start-ups.
Simplifying EPR rules is a prerequisite for a competitive and sustainable future for Europe, GRS underlines. Policymakers should seize the opportunity presented by ongoing legislative processes – including the Omnibus Packages and the planned Circular Economy Act – to deliver genuine bureaucratic relief. A more harmonised EPR regime would allow companies "to invest more in innovation, recycling infrastructure and sustainable design, and less in paperwork", the company concludes.
