Extended Producer Responsibility (EPR) is one of the most important concepts in modern environmental law. Fundamentally, it means holding the producer responsible for the environmental impacts of a product throughout its lifecycle. This approach, unlike traditional waste management understanding, is a framework that holds producers responsible for the environmental impacts of their products throughout the product lifecycle, from design to disposal at the end of its useful life.
From a legal perspective, EPR policies have been adopted by an increasing number of countries and have mandated that producers take responsibility for the proper recycling and disposal of their products.
In the international arena, the concept of EPR was first defined and developed by the OECD in the late 1990s. The United Nations Environment Programme and European Union directives have played a critical role in the spread of EPR practices.
The OECD aims to develop a common understanding of EPR and provide guiding principles for the successful implementation of this approach. Within this framework, countries, particularly the European Union, have introduced various regulations related to EPR in their legislation.
REGULATION IN LEGISLATION
European Union
EPR legislation in the European Union has been developed in line with environmental protection and sustainability goals. The legislation currently in force in the European Union regarding EPR can be summarized primarily under the following directives and regulations.
a. Waste Framework Directive (2008/98/EC)
Forms the legal basis of EPR principles. It defines the environmental responsibility of producers throughout the entire lifecycle of their products. The directive imposes an obligation on member states to implement EPR systems.
b. Packaging Waste Directive (94/62/EC)
Aims to reduce and recycle packaging waste. Generally regulates the responsibilities of producers to collect and recycle packaging waste. Covers all types of packaging (including food, pharmaceuticals, cosmetics, electronic products). The directive envisions increasing recycling rates, reducing packaging waste, and establishing recovery systems.
c. Waste Electrical and Electronic Equipment Directive (WEEE Directive)
Regulates the collection, recycling, and disposal of electronic waste. Makes it mandatory for producers to cover the recycling costs of electronic products.
d. Battery Directive (2006/66/EC)
Aims to contribute to the protection and improvement of environmental quality by minimizing the negative impact of waste batteries and accumulators. It covers all batteries and accumulators regardless of their chemical structure, size, or design, with some exceptions. The directive will be repealed on 18/08/2025 by the New Batteries Regulation ((EU) 2023/1542), which entered into force on 17/08/2023. This replacement is due to the directive having lost its relevance and adequacy over time, as battery usage areas, frequency, and diversity have significantly changed. Certain provisions of the original directive will exceptionally remain in force for a limited period.
e. End-of-Life Vehicles Directive (2000/53/EC)
The directive sets clear targets for end-of-life vehicles. It also prohibits the use of hazardous substances (especially lead, mercury, cadmium, and hexavalent chromium) in the production of new vehicles. The directive sets clear targets for the reuse, recycling, and recovery of end-of-life vehicles, aims to prevent and limit waste from end-of-life vehicles and their components, and to improve the environmental performance of all economic operators involved in the lifecycle of vehicles.
f. Packaging and Packaging Waste Regulation (PPWR) (94/62/EC)
The European Commission has implemented the Packaging and Packaging Waste Regulation (PPWR) to address environmental sustainability and waste management concerns in the European Union. This regulation standardizes and optimizes the management of packaging materials and their associated waste streams with the aim of reducing environmental impact, enhancing recycling, and promoting a circular economy. The key objectives of PPWR include: Waste Reduction, Recycling and Recovery, Extended Producer Responsibility, Market Harmonization, and Increased Use of Recycled Materials. PPWR entered into force on February 11, 2025, with full implementation scheduled for August 12, 2026, following an 18-month transition period.
Turkey
EPR legislation in Turkey is generally developing in parallel with European Union legislation. The legal infrastructure of EPR is established by Environmental Law No. 2872, which adopts the principle of holding producers responsible for the environmental impacts of their products. In addition to the Law, various legislation has been accepted and implemented over time within the scope of EU harmonization.
a. Packaging Waste Control Regulation
This regulation is based on the principle of reducing waste disposal by prioritizing the reuse, recycling, recovery of packaging waste, and/or its use as an energy source. The regulation establishes provisions for collecting packaging waste within the zero waste management system in accordance with the Zero Waste Regulation. It prioritizes material recycling for packaging waste recovery, prohibits sending recyclable packaging waste to landfill facilities, and bars landfill facilities from accepting such recyclable materials.
Under the extended producer responsibility principle, the regulation defines the duties and obligations of packaging producers, entities placing packaged products on the market, and points of sale. It also establishes minimum requirements for packaging and stipulates marking and labeling obligations. For packaging placed on the market after January 1, 2020, financial responsibilities under the “extended producer responsibility” principle can only be fulfilled through the recycling participation fee system.
b. Regulation on the Management of Waste Electrical and Electronic Equipment
In order to protect the environment in a sustainable manner; The regulation is founded on the principles of a circular economy and resource efficiency. Its objectives are threefold: first, to establish a framework for the prevention of waste electrical and electronic equipment (WEEE) formation; second, to establish a framework for the separate collection of WEEE in cases where its prevention is not feasible; and third, to determine the methods and targets for preparing for reuse, recycling, and recovery, with the aim of reducing the amount of WEEE disposed of. It is also crucial to manage waste electrical and electronic equipment within a designated management system, including the zero waste management system, in a manner that ensures neither the environment nor human health are compromised. Furthermore, this regulation aims to implement extended producer responsibility for electrical and electronic equipment manufacturers, while also establishing the administrative, legal, and technical procedures and principles related to strategies and policies.
c. Regulation on the Control of Waste Batteries and Accumulators
The regulation determines issues related to the management of batteries and accumulators and their wastes within a specific management system, including the deposit management system and zero waste management system, based on the principles of circular economy and resource efficiency.
Responsibilities of Producers under EPR
a. Product Design Phase Responsibilities
Producers are obliged to conduct environmental impact assessments at the product design stage. This covers the analysis of environmental impacts throughout the entire lifecycle of the product, starting from raw material selection. Producers should prefer recyclable materials, calculate their carbon footprint, and adopt design criteria with low environmental impact.
In material selection, it is essential to use materials that are suitable for recycling and free from hazardous chemicals. Reusable materials should be preferred, and design approaches that will produce minimum waste should be developed.
b. Production Process Responsibilities
Resource efficiency and emission control are of critical importance in the production process. Producers should reduce energy consumption, optimize water use, and minimize production waste. Sustainable production techniques should be adopted, and clean production technologies should be used.
Monitoring greenhouse gas emissions, reporting environmental performance, and setting emission reduction targets are also among the key responsibilities of producers.
c. Waste Management Responsibilities
Producers are also responsible for the waste management process of their products. In this context, it is necessary to establish a product collection infrastructure, provide recycling points to consumers, and cover collection costs.
Establishing recycling centers, investing in recycling technologies, and developing sorting systems for different types of waste are also among the responsibilities of producers.
d. Legal and Financial Responsibilities
Full compliance with environmental legislation, obtaining necessary permits and documents, regular reporting, and being open to inspections are the legal responsibilities of producers. In addition, they have financial obligations such as covering waste collection costs, providing financial contributions to recycling systems, and supporting environmental funds.
e. Information and Education Responsibilities
Producers are obliged to inform consumers about the environmental performance of their products. Recycling instructions should be provided, environmental awareness training should be conducted, and activities to increase consumer awareness should be carried out.
In terms of internal training, employees need to be provided with environmental education, sustainability culture needs to be spread, and green production practices need to be taught.
f. Monitoring and Reporting Responsibilities
Tracking environmental performance indicators, being open to independent audits, transparent reporting systems, and continuous improvement mechanisms are under the monitoring responsibility of producers.
In terms of technological development, investment in environmentally friendly technologies, R&D studies, innovative recycling solutions, and the establishment of digital tracking systems are expected.
g. Compliance with International Standards
Producers should comply with global sustainability standards such as ISO 14001 Environmental Management System, international environmental agreements, and participate in global reporting initiatives.
Extended Producer Responsibility Number
The Extended Producer Responsibility (EPR) Number is a unique identification number that certifies that producers have fulfilled their EPR obligations. This identifier, which is specific to a given country and typically issued in alphanumeric format, serves to document a producer’s registration within the EPR system. The EPR system is mandatory in most EU countries and serves multiple purposes, including: It facilitates the tracking of products placed on the market by producers, ensures compliance with EPR obligations, and verifies compliance in cross-border trade. It also identifies unregistered producers.
The acquisition of an EPR number is contingent upon the submission of an application to the national EPR authority, the submission of requisite documentation, and the payment of prescribed fees. The application process varies by country and may require periodic renewal. The EPR number is required for: Selling products on e-commerce platforms,Completing customs procedures,Participating in tenders and contracts,Supply chain documentation and verification.
Within the scope of the system, producers have obligations such as regular reporting, data storage and documentation, payment of EPR fees, and updating information. Fulfilling these obligations provides advantages such as ensuring legal compliance, ease of market access, traceability, transparency, and reliability.
There are differences between countries in terms of registration formats, validity periods, costs, and reporting requirements. For example, systems such as LUCID Register in Germany, SYDEREP in France, SCIP Database across the EU, and National Packaging Registry in England are used.
Various sanctions may be applied in case of operating without an EPR number, providing false information, or failing to fulfill reporting obligations. Today, the system is constantly evolving with trends such as digitalization and automatic reporting, blockchain-based traceability, EU-wide harmonization efforts, and increased data sharing.
It is important for producers to start the application process on time, select the correct product categories, follow the reporting calendar, and monitor current legislative changes. EPR number, as an important tool that ensures producers fulfill their environmental responsibilities, is becoming even more effective with continuously evolving legislation and digital transformation.
The Meaning of EPR for Consumers
EPR is a sector-focused policy approach. However, consumer participation is essential for the success of some EPR programs. For example, producers can design packaging to be easily recycled, but if consumers choose to throw away these packages instead of recycling them, high recycling rates would not be possible. For EPR to truly be successful, both producers and consumers need to change their behaviors.
The Future of EPR
The trajectory of EPR will diverge based on market development levels. Developed markets have already established fundamental recycling infrastructure, whereas developing markets still face significant infrastructure deficiencies.
For developed markets, the primary objective is to ensure 75% of plastic packaging is designed for recyclability by 2030, alongside implementing sophisticated systems supporting circular economy principles. Developing markets pursue a more moderate target: achieving 50% recyclable plastic packaging by 2030. The priority in these emerging markets must be establishing comprehensive basic collection and recycling infrastructure to enable effective EPR law implementation.
Extended Producer Responsibility (EPR) continues to gain prominence as a critical instrument facilitating the transition to a circular economy. While EPR initially focused solely on packaging waste management, it has evolved into a comprehensive waste management framework encompassing diverse product categories—from electronic devices to textiles, batteries to automotive components.
The integration of cutting-edge technologies, particularly digital transformation, blockchain applications, and artificial intelligence solutions, has significantly enhanced the efficiency and transparency of EPR systems. Concurrently, international efforts to harmonize EPR practices across jurisdictions are elevating sustainability standards in global trade.
For the EPR system to achieve optimal effectiveness, cohesive collaboration among all stakeholders—producers, consumers, public authorities, and the recycling sector—is imperative. Looking forward, the anticipated strengthening of EPR systems in developing countries is expected to yield substantial improvements in global waste management practices and resource utilization efficiency.