EUROPEN — the European Organisation for Packaging and the Environment — represents the packaging value chain in Brussels and is the principal industry interlocutor on the EU's Extended Producer Responsibility (EPR) regime. In 2025 CIRCPACK was commissioned to run a structured harmonisation review of the recovery organisations that operate the EPR schemes in seven major EU markets, on behalf of EUROPEN's brand-owner membership.
The engagement asked a specific question. The seven principal recovery organisations — CITEO in France, the Dual Systems collectively in Germany, CONAI in Italy, Ecoembes and Ecovidrio in Spain, Fost Plus in Belgium, Verpact in the Netherlands and the UK Extended Producer Responsibility scheme — each operate distinct fee structures, eco-modulation tables, eligibility rules and reporting cadences. Brand owners running multi-market portfolios face a real cost in reconciling these differences. The question was: where could a pragmatic harmonisation step deliver disproportionate value to value-chain participants without requiring legislative change?
Methodology
CIRCPACK structured the review around three layers. First, a comparative legislative map covering each scheme's statutory basis, governance and the obligations placed on producers. Second, an operational comparison of the fee structures themselves — fee tables, the design features that trigger modulation, and the reporting templates that producers submit. Third, a value-chain impact assessment — interviews with brand-owner sustainability and finance leads at twelve EUROPEN member organisations, including several Fortune 500 brand owners, to identify the operational frictions that show up in their day-to-day EPR reporting.
The legislative map drew on the Recycling Intelligence Platform, which covers 71 countries and is continuously revalidated by CIRCPACK auditors inside Material Recovery Facilities (MRFs). The fee comparison used the 2024 and 2025 published tables from each scheme; where a scheme operated multiple regional tables (notably Spain and Belgium) the regional structure was preserved rather than averaged.
Findings: three areas where harmonisation pays for itself
The review surfaced three areas where pragmatic harmonisation steps would meaningfully reduce friction for multi-market brand owners — without touching the underlying member-state legislation. None of the three require new EU regulation; all three can be advanced by recovery organisations co-operating bilaterally or via EUROPEN.
The first is reporting cadence and template alignment. Schemes file annual EPR returns on different fiscal calendars (the German Dual Systems on a calendar year, CITEO on a split-year reporting window, the UK scheme on its own cadence), and each requires data in subtly different formats. A standardised return template — even one that schemes implemented internally and translated locally — would remove a measurable share of the spreadsheet burden in brand-owner EPR teams.
The second is eco-modulation criteria. The reviewers found that, while every scheme now eco-modulates against design features, the features themselves differ — colour for PET, sleeve coverage thresholds, recycled-content requirements, label adhesive types — and the bonus/malus magnitudes diverge by an order of magnitude across markets. Harmonising the design criteria (even without harmonising the fee magnitudes) would mean that a single design improvement could be claimed against every applicable scheme rather than relitigated per market.
The third is the recyclability evidence base. PPWR Article 6 will from 2028 require A/B/C grading across every EU market, and recovery organisations are well placed to align on the certification routes they recognise — RecyClass for plastics, CERTIFY for glass, metals and paper, RECY:CHECK for beverage cartons. Pre-emptive alignment on accredited certifying bodies would mean that one CIRCPACK-issued certificate could underpin EPR claims in every market the brand owner ships to, instead of repeating the certification cost per scheme.
What it means for brand owners
The findings landed with EUROPEN's membership in mid-2025 and have informed the organisation's subsequent engagement with the recovery organisations and the European Commission. For individual brand owners, the operational implication is more pragmatic: until harmonisation is in place, the friction is real, and a portfolio-wide approach is the way to manage it.
CIRCPACK's PPWR Compliance Gap Analysis and Eco-modulation Eligibility services are designed against exactly this multi-scheme picture. The gap analysis maps every SKU against every applicable scheme rule in 6 weeks; the eco-modulation work quantifies the fee saving each design change would generate across markets, so the design programme is sequenced by financial return rather than by which scheme shouted loudest.
About the engagement
CIRCPACK is an independent recycling consultancy, part of the Veolia Group. 25+ years of expertise. Six European offices — Brussels, Amsterdam, Cologne, London, Madrid and Paris — and auditors inside MRFs across the continent. The EUROPEN engagement is one of a series of cross-scheme reviews CIRCPACK has run for industry associations and Fortune 500 brand-owner portfolios in 2024 and 2025.