Challenges to Achieving EPR Goals in Recycling

𝗪𝗵𝘆 𝗰𝗼𝗹𝗹𝗲𝗰𝘁𝗶𝗻𝗴 𝗳𝗶𝗹𝗺 𝗶𝘀 𝗷𝘂𝘀𝘁 𝘁𝗵𝗲 𝘀𝘁𝗮𝗿𝘁 🗑️ Simpler Recycling will bring kerbside film collection to every household in England by 𝐌𝐚𝐫𝐜𝐡 2027. That's the easy bit. The hard bit? Making sure we can actually recycle what we collect. Film makes up ~27% of consumer plastic packaging in the UK. Yet only 7% gets recycled. Once kerbside collection scales up, we could be looking at well over 123kt of material coming through the system annually. But collection is only one part of the equation. We also need: ♻️ 𝐃𝐞𝐬𝐢𝐠𝐧 𝐬𝐭𝐚𝐧𝐝𝐚𝐫𝐝𝐬 that make film actually recyclable (mono-PE/PP, minimal inks, no laminates) ♻️ 𝐒𝐨𝐫𝐭𝐢𝐧𝐠 𝐢𝐧𝐟𝐫𝐚𝐬𝐭𝐫𝐮𝐜𝐭𝐮𝐫𝐞 that can handle the volume and separate by polymer ♻️ 𝐑𝐞𝐩𝐫𝐨𝐜𝐞𝐬𝐬𝐢𝐧𝐠 𝐜𝐚𝐩𝐚𝐜𝐢𝐭𝐲 (mechanical and non-mechanical) to turn bales into usable recyclate ♻️ 𝐄𝐧𝐝 𝐦𝐚𝐫𝐤𝐞𝐭𝐬 willing to pay for recycled content and absorb the cost premium ♻️ 𝐏𝐨𝐥𝐢𝐜𝐲 that closes the gap between what's technically recyclable and what's economically viable And without strong end-market demand, investment in new capacity won't happen. Last we published a report which identifies 𝐰𝐡𝐚𝐭 𝐰𝐨𝐫𝐤𝐬 in Europe, and 𝐰𝐡𝐚𝐭 𝐝𝐨𝐞𝐬𝐧'𝐭. Germany collects film at scale, but still 𝐥𝐨𝐬𝐞𝐬 𝐚 𝐭𝐡𝐢𝐫𝐝 𝐭𝐨 𝐫𝐞𝐬𝐢𝐝𝐮𝐚𝐥 𝐰𝐚𝐬𝐭𝐞. Most European film recycling focuses on PE only. PP and mixed materials? Still struggling to find routes. 𝘛𝘩𝘦 𝘭𝘦𝘴𝘴𝘰𝘯𝘴 𝘢𝘳𝘦 𝘤𝘭𝘦𝘢𝘳: Collection without infrastructure is just stockpiling. Infrastructure without end-markets is just expensive disposal. So what could the pathway forward look like? 1️⃣ Raise pEPR base fees to cover the true cost of recycling film (~£1,200/tonne) 2️⃣ Set specific recycling targets for films to drive investment 3️⃣ Shift to mono-polyolefin packaging with minimal printing 4️⃣ Build domestic end markets through procurement commitments and verified recycled content 5️⃣ Stop incentivising exports through PRN/PERN reform The 𝐔𝐊 𝐏𝐚𝐜𝐤𝐚𝐠𝐢𝐧𝐠 𝐏𝐚𝐜𝐭 brings together businesses, governments, and NGOs to tackle exactly this. We know there's 𝐧𝐨𝐭 𝐚 𝐬𝐢𝐧𝐠𝐥𝐞 𝐬𝐨𝐥𝐮𝐭𝐢𝐨𝐧. We need elements across the value chain to come together: design, collection, sorting, reprocessing, end markets, policy, and buy-in. The Exec Summary is linked in the comments. 👇 𝙁𝙤𝙡𝙡𝙤𝙬 𝙢𝙚 𝘧𝘰𝘳 𝘤𝘰𝘮𝘮𝘦𝘯𝘵𝘢𝘳𝘺 𝘰𝘯 𝘵𝘩𝘦 𝘤𝘪𝘳𝘤𝘶𝘭𝘢𝘳 𝘦𝘤𝘰𝘯𝘰𝘮𝘺, 𝘸𝘢𝘴𝘵𝘦, 𝘳𝘦𝘴𝘰𝘶𝘳𝘤𝘦𝘴, 𝘢𝘯𝘥 𝘮𝘰𝘳𝘦. #CircularEconomy #PlasticFilm #SimplerRecycling #UKPlasticsPlact #Packaging #Recycling #EPR #WasteManagement #CircularLiving #ResourcesAndWaste

Extended Producer Responsibility (EPR) is widely promoted as a policy that drives higher recycling rates, but the empirical evidence does not support this claim. The argument that EPR jurisdictions outperform non-EPR jurisdictions relies on flawed cross-sectional comparisons that fail to control for confounding variables like system maturity, infrastructure, and demographics. Research consistently identifies accessibility and collection convenience — not producer responsibility legislation — as the primary drivers of recycling performance. Longitudinal data from Canadian provinces tells a damning story. Despite cost increases of 100–250% over the past decade, recycling rates in British Columbia, Ontario, Manitoba, and Quebec have stagnated, declined, or shown only marginal gains. EPR has functioned as a cost redistribution mechanism, not an environmental performance driver. Three structural factors explain this: diminishing returns in mature systems, the "evolving tonne" problem as packaging shifts toward lightweight composites incompatible with existing infrastructure, and the absence of viable end markets for difficult-to-recycle materials. EPR has legitimate applications as a financing tool, particularly in jurisdictions with immature infrastructure. But treating it as a recycling policy generates unrealistic expectations. Without complementary interventions addressing infrastructure, end markets, and packaging design standards, EPR cannot deliver durable improvements in recovery performance. #ExtendedProducerResponsibility #EPR #CircularEconomy #WasteManagement #RecyclingPolicy #PackagingWaste #SustainabilityPolicy #EnvironmentalPolicy #ProducerResponsibility #WasteReduction

My op-ed titled 'The missing link in India's battery waste management' in The Hindu on 5th August, 2025. Brief Summary: India's rapid push for EVs and renewable energy is commendable, but it's creating a silent crisis: battery waste. Without a robust recycling framework, our green ambitions could lead to severe environmental damage. The core issue lies with the Extended Producer Responsibility (EPR) rules. A cornerstone of this system, the EPR floor price, is meant to compensate recyclers. However, the price is currently too low to cover the real costs of safe recycling. This low price drives legitimate recyclers out of the market, allowing fraudulent operators to thrive. These informal actors often dump hazardous materials and issue fake certificates, a failure we've seen before with plastic waste. This not only harms the environment but also threatens India's economic future, with experts predicting over $1 billion in foreign exchange losses by 2030 if the country fails to recover valuable minerals from these batteries. To fix this, we need to: ✅ Raise the EPR floor price to a fair, globally comparable level that covers the full cost of recycling. ✅Strengthen enforcement with better audits and strict penalties for fraud. ✅Formalize informal recyclers to expand our national capacity safely. Read the full article at the link below: https://lnkd.in/g9eiENWY #EVs #BatteryRecycling #Sustainability #CircularEconomy #EPR #India #GreenGrowth #NetZero2070 #Environment #TheHindu #ExtendedProducerResponsibility #EPR #Batterywaste #RareEarths #LithiumIonBatteries #OpEd #EPRFloorPrice

Why Recycling Plastic Film is Challenging (and Why We Do It Anyway) Recycling flexible film into a product that can be used again in flexible packaging is a complex process.  Despite the challenges, NOVA Circular Solutions is making significant strides to increase the supply and improve the quality of recycled polyethylene (rPE) made from flexible films to enable circularity.  Here's why recycling plastic film is so challenging and why we continue to pursue it. The Challenges of Plastic Film Recycling 1. Securing the Feedstock: Plastic films are thin and light and often intermingled with other materials making collection and sorting a critical task. Ensuring a consistent supply of clean plastic film feedstock requires either meticulous manual sorting or state-of-the-art automated sorting technology to ensure the consistency of feedstock necessary to produce a high quality rPE. 2. Specialized Equipment: Recycling plastic film requires specialized processing equipment that can shred, wash, dry and extrude the thin, flexible material without causing jams at high production rates. 3. Quality Control: Maintaining the quality of rPE to meet industry standards for flexible packaging requires robust manufacturing practices and sophisticated quality control testing. 4. Regulatory Compliance: Navigating the complex web of regulations governing plastic recycling for food-grade materials requires meticulous attention to detail and adherence to stringent traceability standards. It is important to make sure rPE is certified and compliant for its intended use, especially for food contact applications. Despite these challenges, the benefits of recycling plastic film are undeniable: 1. Environmental Impact: Recycling reduces the amount of plastic waste in landfills and oceans, mitigating pollution and conserving natural resources. 2. Economic Benefits: Creating a market for recycled plastic film can stimulate economic growth and create jobs in the recycling industry. Our Approach NOVA Circular Solutions is at the forefront of tackling these challenges. Our first mechanical recycling facility for PE film is now online. The SYNDIGO1 facility located in Connersville, IN represents a significant step forward in the recycling industry, aiming to produce high quality SYNDIGO recycled PE. We employ cutting-edge technologies and rigorous manufacturing processes to ensure the quality and safety of the recycled products. By working closely with regulatory bodies and industry partners, NOVA Circular Solutions is setting new standards for plastic film recycling. While recycling plastic film is challenging, the environmental and economic benefits make it a worthwhile endeavor. NOVA Circular Solutions is leading the way, demonstrating that with innovation and commitment, we can overcome these obstacles and make a positive impact on our planet.

Germany collects 64% of its textile waste. Then exports 80% of it unsorted. That's not a circular economy. That's a very expensive logistics operation with someone else managing the ending. Boston Consulting Group (BCG) and Circular Economy Initiative BDI just published the most rigorous circular economy study I've seen for German industry. Their textile chapter lands one hard truth: collection rates are irrelevant if sorting infrastructure doesn't scale. We've spent a decade measuring circularity by collection. That's the wrong metric. What matters is what happens after the bin. In Germany — Europe's collection leader — four out of five collected garments leave the country before anyone checks what's in them. They get sorted in Poland, in Pakistan, sometimes nowhere at all. A fraction comes back as recycled fibre. Most doesn't. The fix isn't collecting more. It's mandating minimum domestic sorting ratios before export is permitted. Tie EPR fee eligibility to sorting outcomes, not collection volumes. €200–220 million in sorting infrastructure investment to 2045 — that's BCG's estimate. Against a €5.4 billion annual GVA upside. That's not a budget question. That's a political will question. What's blocking the sorting investment where you operate? #CircularFashion #EPR #TextileRecycling #DenimDeal #ESPR #FibreToFibre #FashionIndustry #Sustainability #CircularEconomy #TextileInnovation

Extended Producer Responsibility is one of the main tools to finance #waste management in the EU but how useful is it to foster the #circularity we need to increase EU’s #competitiveness & #strategicautonomy? 🤔 We are releasing a study which proposes a framework to not only address the challenges of current #EPR systems but also transform these systems into catalysts for the circular economy transition. After 30 years of implementation, EPR has successfully mobilized resources to cover parts of waste management but EU’s circularity is not increasing (in fact, waste generation continues to rise whilst reuse and repair decline). The study also delves into the performance of different EPR systems (oversight, enforcement, reporting, collection performance, cost-coverage, transparency, free-riding). The global context has shifted dramatically since EPR was first implemented. Supply chain disruptions, energy security concerns, and increasing demand for critical raw materials have highlighted the EU's resource vulnerability. In this new context, EPR must evolve from a waste management financing mechanism to a catalyst for a systemic shift toward resource efficiency and circularity that underpins the EU's competitiveness and strategic autonomy. We propose a two-pillar approach to address the current challenges and build on the new global context: 1- System Optimisation: Creating harmonised EU EPR principles and establishing a European EPR advisory body to reduce administrative burden, combat free-riding, and create a true single market for circular economy. 2- Circular Economy Enabler: Expanding EPR to finance prevention, reuse, and repair – not just waste management – through repair funds and reuse infrastructure. Connect EPR to broader resource efficiency tools and create global EPR frameworks to level the playing field. Currently only the 1st pillar is discussed in Brussels whilst the 2nd one is neglected. This triggers what in the study is referred to as the “EPR paradox” which occurs when systems designed to manage waste become barriers to circularity options that are higher in the waste hierarchy. For a lot more info I invite you to read the study! 👇

While writing two posts in one day might not be the wisest move, I feel this one deserves an exception. A new report titled The Textile Recycling Breakthrough launched earlier today. While I’m still processing the full document and considering a longer deep dive either tomorrow or over the weekend, there are a few key things I would like to bring up. The cost gap between virgin PET and textile-to-textile (T2T) rPET is massive: €1,529 per ton, according to the report. Quickly looking up the prices, the PET price in China has been hovering around €750 to €800 per ton, even lower than the €950 estimated in the report. This puts the gap at nearly a threefold premium. What is striking is that the common belief that scale will bring the cost of recycled materials down does not hold up under scrutiny. The report shows that scaling T2T processes only reduced costs by 15 percent. So we can once and for all put the idea that economies of scale will magically fix everything to rest. Moving to the more critical part. The report highlights that €829 of the gap, roughly 55 percent, is expected to be covered by Extended Producer Responsibility (EPR) fees. This raises a key question I have been turning over. If EPR fees are used to subsidize the cost of recycled materials, are we not essentially just rerouting the money brands would have spent directly on the recycled feedstock anyway? In both cases, brands still pay, just through a different channel. More realistically, these costs are likely to be passed down to consumers. That means the end consumer ends up footing the bill for scaling recycled fibres for years and years before any meaningful volumes start flowing, effectively paying in advance for the output of their contribution. Moving to the topic of environmental impact, the report references CO₂ savings drawn from a 2023 JRC study. But this study largely looks at plastics in general, such as bottles and packaging, not textile-to-textile recycling. And textiles are a far more complex feedstock. Extrapolating bottle to bottle data to textiles is a stretch, to say the least. So the true impact of T2T recycled fibres is likely higher than what is reported. One number in particular did not sit right with me. Glycolysis, a chemical recycling method, is reported at 0.4 kilograms CO₂ equivalent per kilogram. For context, mechanical PET recycling typically lands around 0.45 kilograms CO₂ equivalent per kilogram. So we are being told that a more energy and chemically intensive process has a lower footprint than mechanical? That does not quite add up. I look forward to exploring this further in a separate post. To end, if the environmental benefits are overestimated and the financial burden is potentially shifted to consumers for a solution with marginal environmental gains, we must ask ourselves whether we are investing billions in the right path. Something to reflect on.

🔊 Policy alone won’t save our textiles! As Extended Producer Responsibility (EPR) moves from concept to implementation, one thing is clear: regulation alone won’t build a circular textile economy. We need infrastructure. We need investment. And most importantly, we need alignment across the entire value chain. The latest Circularity.fm episode is a recording of our CIRCULAR REPUBLIC festival panel, where I moderated a conversation with leaders from brands, recyclers, and policy to unpack what a functioning EPR system really requires — beyond the legislation. Here’s what we tackled: 🧱 Infrastructure gaps: Without large-scale collection and sorting capacity, recycling can’t scale. But who will build it — and who will pay? 💶 EPR fees: Setting the right fee is a balancing act. Too low, and recycling isn’t viable. Too high, and producers resist. So how do we align incentives? 🔁 Feedstock flow: Recyclers urgently need sorted, high-quality material. Until systems are in place, scaling deep-tech innovations remains stuck in “pilot purgatory.” 💡 Voluntary vs mandatory: Can early voluntary pilots help shape better regulation? And how do we ensure they’re credible and impactful—not just green PR? 🤝 Alignment is everything: There’s still friction between what brands want, what waste operators need, and what policy envisions. But only by designing this system together—with honest trade-offs and shared goals—can we make EPR a success. 🎧 If you’re working in textiles, circularity, or policy: this conversation is for you. Link to the full episode in the comments. 👇 Steffen Gerlach, Marie Nawrocki, Julia Haas, Sophie Herrmann thank you for joining me on stage. Let’s move beyond intentions—and build a system that works in practice. #CircularEconomy #EPR #Textiles #CircularityFM #CRF25 #SystemChange #CircularRepublic

Recycled polyester is everywhere — but so is the liability. A review of the 2025 textile supply-chain landscape points to a growing vulnerability in fashion’s most widely used sustainability claim: Data Integrity. Public industry data indicates that while a large majority of brands plan to increase recycled polyester (rPET) use, the overwhelming share of feedstock still originates from plastic bottles, not post-consumer textiles. Textile-to-textile recycling remains limited to pilot scale. Meanwhile, bottle-based recycling has been industrialised. This is no longer just an environmental debate. It is a compliance and financial risk. EU policy is swiftly moving sustainability claims from voluntary marketing language to legally substantiated disclosure. Under the Ecodesign for Sustainable Products Regulation (ESPR) and the Green Claims Directive, generic “recycled” claims without verifiable origin data will not hold. Three pressure points are now converging: - The Data Blind Spot: Many LCAs still rely on secondary industry averages rather than primary, site-specific tier-1/tier-2 data. This weakens claim robustness before regulators. - The Reporting Risk: Variations in feedstock attribution can materially affect reported Scope 3 emissions, creating volatility in carbon disclosures. - The Material Trade-off: Peer-reviewed research indicates mechanically recycled polyester fibers are shorter and more brittle, with studies suggesting significantly higher microfiber shedding rates (+55%) compared to virgin polyester. Taken together, these factors shift traceability from a sustainability function to a CFO-level risk question. Brands that treat recycled-content claims as a checkbox will face rising compliance costs and audit friction. Brands that invest early in verified chain-of-custody and primary data capture will convert transparency into operational resilience. The bottom line: If you cannot digitally verify the origin and flow of your recycled fiber, you don’t have a sustainability strategy. You have a marketing risk. Where do you see the largest data blind spot in your supply chain today — feedstock verification (proving it’s not just bottles) or Tier-2 processing visibility? 👇 Let’s discuss in the comments. Sources - Textile Exchange — Preferred Fiber & Materials Market Report 2024 McKinsey & Company — The State of Fashion European Commission — ESPR; Green Claims Directive; Digital Product Passports Ellen MacArthur Foundation — The New Plastics Economy Changing Markets Foundation — Spinning Greenwash Report 2024 Nature Communications — Research on microfiber shedding

Europe’s textile waste could fill c.80 football stadiums each year, over the decade. By 2035, post-consumer textile waste in Europe is projected to reach ~18Mt annually, up from ~13Mt today (+36%). Less than 1% is recycled back into new textiles. Most textiles never reach recycling. They are lost early in the system through low collection rates, limited sorting depth, and infrastructure that was not built to separate materials at the level required for recycling. What reaches recyclers is often inconsistent, contaminated, or too fragmented to process efficiently. At the same time, recycled fibers remain structurally more expensive than virgin alternatives. Chemical recycling is capital intensive. Pre-processing requires additional steps. Energy and operational costs are higher. Recyclers operate with negative margins, while brands work within tight cost structures and short product cycles. This creates a structural disconnect across the value chain. Three shifts start to make this investable: • Collection moves from optional to systematic Dedicated collection channels, in-store take-back, and EPR-funded systems increase capture rates and reduce contamination at source • Sorting evolves into an industrial capability Advanced sorting technologies, fiber identification, and standardized grading create consistent, recycling-ready feedstock at scale • Pre-processing and recycling scale together Investment in cleaning, shredding, and material preparation aligned with recycling capacity improves yields and reduces downstream costs • Demand is secured, not assumed Long-term offtake agreements, minimum recycled content requirements, and pricing mechanisms that reflect true end-of-life costs create predictable revenue streams • Risk is shared across the system CAPEX support, guarantees, and coordinated policy frameworks reduce first-mover risk and enable early infrastructure build-out Without these shifts, the system continues to expand in volume while losing material, value, and economic viability upstream. Source: BCG x ReHubs — Advancing textile circularity (2026)