Joint industry concerns on emerging state-run PRO models

The undersigned organisations wish to express their concern about a growing trend in several Member States to establish State-run Producer Responsibility Organisations (PROs) within new or existing Extended Producer Responsibility (EPR) schemes.
This development raises concerns in relation to three core and interlinked principles that industry has consistently defended when designing effective EPR systems:
1. EPR systems must remain producer-driven, transparent and accountable, as required by Article 8a of the Waste Framework Directive;
2. Harmonisation across the EU is essential to ensure a functioning Single Market and to reduce unnecessary administrative burdens;
3. A clear separation of roles between regulator, supervisor and operator is needed to uphold good governance and avoid conflicts of interest.