One in – two out. What Would a Cut in Bureaucracy in the European Union Mean for Extended Producer Responsibility Regulations?
helmut.minor • 28. Januar 2025
envenance on compliance.
The German chancellor candidate Friedrich Merz is committed to reducing bureaucracy in the European Union. https://www.friedrich-merz.de/merzmail/merzmail-03-2025/ In this context, he advocates the principle of "one in, two out" – meaning that for every new burdensome regulation, two existing and still effective regulations must be abolished. It is a bit ironic in the view of the author that Merz emphasizes a cut in bureaucracy, particulary regarding legal regulations at the same time when the new Packaging Regulation PPWR has been officially published – a regulation of 124 pages that replaces the Packaging Directive with merely 14 pages.
The European Union (EU) is known for its extensive regulatory framework, particularly in areas concerning environmental sustainability and waste management. One of the key mechanisms in this domain is Extended Producer Responsibility (EPR), which mandates that producers take responsibility for the entire lifecycle of their products, including waste management and recycling. However, EPR regulations are often criticized for being overly bureaucratic, with complex reporting obligations, varying national implementations, and high compliance costs. A reduction in bureaucracy within the EU could have significant implications for EPR policies.
Potential Benefits of Reduced Bureaucracy
- Simplified Compliance for Businesses
Many companies, particularly small and medium-sized enterprises (SMEs), struggle with the administrative burden of EPR compliance. A streamlined approach with harmonized regulations across EU member states could reduce complexity, making it easier for businesses to fulfill their obligations without excessive paperwork and redundant national registration processes. - Increased Efficiency in Waste Management
Bureaucratic inefficiencies can slow down the implementation of waste collection and recycling initiatives. Cutting red tape could enhance collaboration between stakeholders, improve data-sharing mechanisms, and allow for faster adaptation to technological advancements in recycling and circular economy practices. - Cost Reduction for Producers
Compliance with EPR regulations often comes with high administrative costs due to the need for extensive reporting, audits, and cross-border regulatory variances. Reducing bureaucratic hurdles could lower compliance costs, allowing companies to allocate resources more effectively toward sustainable innovation and eco-design improvements. - Encouraging Cross-Border Trade and Innovation
With fewer bureaucratic obstacles, businesses operating in multiple EU countries could benefit from a more standardized regulatory environment. This is particularly interesting for companies that market their products and come from the outside of the European Union.
Potential Risks and Challenges
- Risk of Lower Environmental Standards
While reducing bureaucracy can increase efficiency, there is a risk that essential environmental safeguards could be weakened. Simplification should not lead to deregulation that undermines the EU’s ambitious sustainability goals. - Uneven Implementation Among Member States
EPR systems vary across EU countries, with some having more advanced infrastructures than others. If bureaucratic cuts are not implemented carefully, disparities between national approaches could widen, making enforcement and oversight more challenging – even more than already today. - Transparency and Accountability Concerns
Robust regulatory frameworks help ensure compliance and prevent greenwashing. Cutting administrative requirements should not come at the cost of transparency, as this could lead to reduced accountability among producers and recyclers.
Leave EPR to the Free Market?
Should EPR regulations be sacrificed, the author is convinced that Extended Producer Responsibility (EPR) would not work effectively without such regulations. Waste is an external effect that cannot be left to the free market alone. EPR relies on legally binding frameworks to ensure that producers take responsibility for the environmental impact of their products throughout their lifecycle. Without regulations, several key challenges would arise:
- Lack of Enforcement – Without mandatory rules, many businesses might not voluntarily invest in waste management or recycling efforts, leading to increased environmental pollution.
- Market Imbalance – Companies that choose to implement sustainable practices could face competitive disadvantages compared to those that do not, creating an uneven playing field.
- Insufficient Funding for Recycling Infrastructure – EPR schemes fund recycling and waste management through producer contributions. Without regulations, there would be no obligation for producers to contribute, potentially leading to underfunded waste management systems.
- Ineffective Circular Economy Goals – The EU's ambitious sustainability and circular economy objectives depend on structured EPR frameworks to drive eco-design, waste reduction, and material recovery.
The Path Forward: Balancing Efficiency and Responsibility
To achieve an optimal balance, the EU should focus on harmonizing EPR requirements across member states, digitizing reporting obligations, and eliminating redundant or outdated processes. Standardized compliance mechanisms, such as a centralized EU-wide EPR registration and reporting platform, could enhance efficiency without compromising environmental integrity.
Ultimately, a reduction in bureaucracy should aim to make EPR regulations more effective rather than weaker. By streamlining administrative processes while maintaining strong oversight, the EU can create a more business-friendly environment that also upholds its sustainability commitments. While reducing bureaucracy can make EPR more efficient, completely removing regulations would likely lead to its failure, as voluntary initiatives alone are rarely sufficient to ensure widespread compliance and accountability. Cutting out the EPR rules completely is not the right way.
The Ecodesign for Sustainable Products Regulation (ESPR) , part of the EU’s 2020 Circular Economy Action Plan and the European Green Deal, introduces the DPP to transform how products are tracked and managed across their lifecycle. Its core purpose is to support circular business models by providing accessible, reliable, and standardized data across the value chain. By digitizing lifecycle information, the DPP empowers recyclers with material-specific insights, enables manufacturers to monitor compliance, and helps consumers understand durability, repairability, and sustainability aspects. If implemented effectively, the DPP could become an important tool to drive real change in how products are produced, used, and recovered. But with the growing influence of Omnibus IV , a new question arises: Can the DPP remain a tool for circular innovation as it takes on a growing regulatory role under Omnibus IV? 1. Omnibus IV and the potential change of role of the DPP In a recent webinar, Arianee emphasized the alignment between the DPP and the Omnibus IV simplification initiative. A central proposal is to use the DPP to reduce reporting burdens for manufacturers by streamlining declarations of conformity, customs processes, and data exchange with authorities. The Omnibus IV package , published by the European Commission in May 2025, confirms this trajectory. From a regulatory standpoint, the DPP is becoming a powerful tool for administrative efficiency and digital integration across the Single Market. But this evolution also raises concerns. The DPP was designed to enable circular value creation , not just fulfill compliance obligations. If it becomes primarily a reporting mechanism for regulators, it could undermine its potential to support closed-loop systems, foster reuse, and unlock sustainability innovation. A balanced path is needed. One that aligns regulatory reliability with the practical needs of circular economy stakeholders. While regulatory alignment through Omnibus IV may provide much-needed structure , it risks narrowing the DPP’s functional scope . What qualifies as "compliance data" may fall short of what circular actors need, such as disassembly instructions, component-level material passports, or real-time usage data – and foremost inputs for a circular design of products. 2. Proof of concept: promising, but no common standard yet A pilot project launched in October 2024 by ecosystem , Fnac-Darty , Beko, Envie and Arianee marks one of the first large-scale implementations of the DPP for household appliances. Over two years, the initiative introduces digital passports built on Arianee’s open-source blockchain infrastructure , assigning each device a unique identity. These passports track lifecycle events, from manufacturing and market entry to repair, resale, and recycling. They also act as digital maintenance logs , consolidating technical specifications, repair history, and environmental impact into one accessible record. Crucially, the project is based on a non-proprietary, interoperable system , allowing data exchange between manufacturers, service providers, and recyclers. It demonstrates that the technology exists and that multi-stakeholder collaboration is possible. Yet a major obstacle remains: there is still no harmonized standard , neither sector-specific nor EU-wide. Without a shared framework, true interoperability remains out of reach. The ambition is clear, but the supporting infrastructure and governance lag behind. 3. Our impressions While the Digital Product Passport holds significant promise, our current impression is that its focus remains limited in several key areas, particularly when it comes to end-of-life processes and industrial usability. Strong emphasis on use phase: The DPP currently seems centered around extending product life, especially through improved repairability and maintenance transparency. However, its potential to support end-of-life processes seem less developed. Designed with the consumer in mind: Much of the DPP’s current design appears geared toward private end users, providing information that helps them repair or understand the sustainability of a product. In contrast, there seems to not be too much focus on industrial users. Questions around data quality and control: Another open issue is the quality of the data entered into the DPP. Since its usefulness depends on accurate and comprehensive input, the question arises: Who validates this information, and how is data quality ensured across different actors and sectors? At this stage, we see a lack of clear governance mechanisms for data verification. A tool for customer engagement, but what about EoL? From the manufacturer's perspective, the DPP seems to offer value primarily as a customer retention tool, for example, through transparent communication about product features and sustainability. However, it remains unclear what incentive manufacturers have to provide detailed and useful end-of-life data, especially if it does not serve their immediate business interests. Looking ahead, several important questions remain unanswered: Can the DPP be scaled to support end-of-life processes at an industrial level? Is it possible for recyclers to extract and interpret high-volume data to improve recycling workflows? Could the DPP support the development of a functioning secondary market for spare parts and recovered materials that is economically viable? In our view, there may currently be more expected of the DPP’s role in end-of-life than it is yet able to deliver. Much will depend on how the system evolves in the coming years—both technically and in terms of regulatory and industry adoption. 4. So, catalyst or casualty? At this stage, the DPP is both : For one it is a catalyst in its intention, design, and pilot implementations . On the other, it is a potential casualty in its institutional framing under Omnibus IV . Whether it fulfills its promise will depend on political will, cross-sector collaboration, and a conscious effort to anchor the DPP in real-world circular value, not just administrative logic. To succeed, the DPP must do more than simplify processes. It must enable circular outcomes. Only if the DPP offers tangible value to both regulators and market actors can it truly fulfill its intended role as a driver of sustainability in Europe’s product economy. And that means putting data, users, and material recovery - not just regulatory compliance - at the center of its evolution.
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