Brussels, 17 December 2025 – The PRO Circularity Alliance has submitted a Position Paper to Commissioner Jessika Roswall addressing recent developments in some Member States that point towards the establishment of State-run Producer Responsibility Organisations (PROs) and the reclassification of EPR fees as public revenue.

In the paper, the Alliance raises serious concerns that such approaches could weaken the foundations of Extended Producer Responsibility in Europe. Over the past decades, industry-led EPR systems have been a key driver of improved collection, recycling, eco-design and innovation. Centralising these systems under State control risks diluting accountability, reducing incentives for producers to design better products, and limiting the flexibility needed to achieve circular economy and climate objectives.

The Position Paper calls on the European Commission to take a clear and consistent approach at EU level. In particular, the Alliance urges the Commission to:

• Reaffirm that producer responsibility must remain industry-driven
• Ensure that EPR fees are recognised as dedicated environmental contributions and reinvested directly into circular economy
• Discourage the establishment of single, State-run PROs, except in clearly justified and exceptional circumstances
• Safeguard PRO independence, transparency, competition and innovation in future EU legislation and revisions
• Promote EU-wide best practice principles for accountable, efficient and effective EPR governance

The Alliance underlines that Europe’s circular economy relies on robust, industry-led EPR systems. Moves towards re-centralisation risk reversing progress made in waste prevention, recycling performance and sustainable product design.

Read the full postion paper here.