WWF

World Wide Fund for Nature (WWF), the world’s leading conservation organization working in 100+ countries, supports packaging EPR as a core tool to reduce unnecessary plastics, scale reuse and recyclability, and build effective circular systems for packaging. WWF urges legislators to harmonize EPR frameworks across jurisdictions, base performance targets on data-driven needs assessments, and ensure strong producer financial responsibility with performance-based incentives that drive reduction, reuse, and high-quality recycling.

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This submission is provided for visibility and comparison only; its inclusion does not imply endorsement by CIRCLE, OPLN, or any other contributor

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In this section

Recommendations for Circular Policy & EPR for Packaging Policies:

Harmonization

Establish targets from needs

Incentivize the 3 R's

As the world’s leading global conservation organization, WWF works in 100 countries and at every level, collaborating with people around the world to develop and deliver innovative solutions that protect communities, wildlife, and the places in which they live. WWF advocates to eliminate the single-use plastic that we don’t need, shift to sustainable sources for the plastic that we do need, and improve our material system to collect, reuse, recycle, and compost all plastic that we use. EPR at the state, federal, and international levels will provide infrastructure, economic incentives, and accessibility for consumers to reduce, reuse, and recycle packaging in a circular system.

Recommendations for Legislators Developing EPR for Packaging Policies

1. Harmonize critical elements and definitions across states

EPR has already passed in seven states and is under consideration in several more. As more states and the federal government consider EPR, harmonization will be critical to streamline implementation processes, enable producer compliance, and ensure consistency across all jurisdictions. This includes standardized definitions (e.g. “producer,” “covered material,” “reuse,” etc.), harmonized infrastructure development, consistent education and outreach messaging, and more. Harmonization can enable cost-effectiveness and support the development of regional infrastructure. Harmonization can also ensure better and more consistent data collection and quality, resulting in more effective implementation. At the same time, state and regional flexibility should be allowed to ensure the legislation is fit-for-purpose.

2. Establish EPR performance targets based on the needs assessment

Performance targets in EPR (including, but not limited to, source reduction, reuse, PCR, and rates of return/collection) should be required by legislation, but the targets themselves should be data-based and determined after the needs assessment is completed. A needs assessment evaluates existing waste management systems, identifies gaps, and provides crucial context, data, and information to inform ambitious and achievable targets. Setting targets based on the needs assessment will avoid unintended consequences and enable targets to be modified and evolved based on changing data availability and economic conditions. PRO target setting decisions should be reviewed by the appropriate government oversight agency to ensure sufficiency. Multiple states including Minnesota, Colorado, Washington, and Maryland have taken this approach.

Performance-based funding mechanisms - where payments are linked to achieving specific targets, such as collection rates, processing efficiency, and contamination rates – should be considered to support innovation and ensure all costs are covered.

3. Ensure producers are financially responsible and incentivize shifts toward reduction, reuse, and recyclability.

Full financial responsibility from producers is highly preferred, however, shared responsibility is an acceptable compromise, when producers are responsible for 90% or more of the program. Financial responsibility split can change over time, and some programs phase this split gradually to increase the PRO’s financial responsibility after start-up costs, as the waste management system matures.

Well-designed EPR must both drive increased recycling rates and incentivize reduction and reuse. Eco-modulation, where fees include a bonus or malus based on sustainability, reuse, and recyclability within material categories, must be utilized. Regardless of approach, it will be important to harmonize calculation methodologies and categories for setting fees across geographies, including eco-modulation approaches to fees.

For more information, please consider these external resources: