A guide to the proposed BSI standard for Producer Responsibility Organisations and what it means for EPR in Europe
Overview
A new BSI project is setting out rules for how Producer Responsibility Organisations or PROs should operate under Extended Producer Responsibility or EPR. The aim is clearer roles, consistent data, and shared practice across schemes. This is a really important time to be aligning on EPR because the EU now has a single binding Packaging and Packaging Waste Regulation (PPWR). However, Member States run very different EPR systems today. Want to know more about the practical implications for producers, PROs and compliance teams? Read on and this blog will help you understand what is coming;
EPR makes producers responsible for end of life management of products or packaging. Legislation is moving from a Directive led national patchwork of rules, toward a common EU Regulation. The PPWR entered into force on 11th February 2025 and requirements begin to apply from 12th August 2026 onwards. That changes the baseline for compliance across EU markets.
At the same time BSI has opened project ISO/NP 26259 Circular Economy to develop a standard for PRO operation. A Producer Responsibility Organisation (PRO) for EPR is an organization that collects fees from businesses to fund the management of their waste, covering costs like collection, sorting, and recycling. PROs act as intermediaries, ensuring that companies placing packaging on the market comply with EPR laws by handling the financial and administrative responsibilities .
The draft standard aims to define scope and operational requirements for organisations that run EPR schemes. If adopted this could create a shared reference for quality, transparency and data.
The baseline today
European EPR schemes are diverse. Some countries use single national schemes for packaging. Others have multiple competing PROs. Fee rules, data collection and reporting formats differ across Member States. That variation might increase cost and risk for firms selling in multiple markets. Industry groups and analysts have been documenting this heterogeneity and weighing up the pro’s and con’s of each for years, but there is no clear winner based on the recycling rates we see today.
Independent reviews and OECD analysis show policy makers are also expanding EPR from packaging, electronica and batteries into new product groups such as textiles and plastic pollution. The common theme is a move toward more oversight, standard reporting, and financial transparency.
What a PRO standard could deliver
A practical standard for PROs would not replace regulation. It would work with regulation to deliver measurable improvements in three areas.
- Governance and accountability
Clear rules on how a PRO is structured, how decisions are made, and how conflicts of interest are managed. This reduces legal and reputational risk for producer members that register with a PRO. - Data and reporting
Standard data definitions, templates and audit requirements. That makes international compliance management and reporting easier and supports compliance with PPWR style obligations. - Fee setting and collection practice
Transparent methods for calculating fees and allocating costs. The approach to fees differs wildly across Europe. A common methodology, closer to Article 8 of the Waste framework Directive should help producers forecast obligations and compare PRO offers.
These are realistic, implementable outcomes. The value is lower compliance overhead for producers and fewer surprises for regulators. Surely a win for all producers.
What this means for producers and compliance teams
Understanding the regulatory landscape is just the start. How business operations are impacted and managing responsibilities, often independently or autonomously from head-office, is where the real risk-reward balance plays out.
- Know your obligations
Map which product categories you sell to each Member State and which EPR schemes apply. Products and materials may include; packaging, waste electrical and electronic equipment (WEEE) or e-waste, and batteries. Many EU countries also have or are introducing EPR for other product groups, including textiles, vehicles, furniture, mattresses, and construction materials. Regulations like PPWR have central rules but local implementation still matters. - Ask PROs for standardised data
Request fee methodologies and reporting templates. If a PRO follows a recognised standard you will get more consistent data and easier audits. - Test assumptions
Model your costs under multiple fee scenarios, including higher collection or recycling costs and even material substitution to access lower material rates. Use conservative volumes and conservative recycling yield assumptions. - Join conversations
Standards are shaped by participants. Companies that speak up get practical rules that reflect real supply chain constraints. The BSI consultation is open until the End of November. Find out more here.
How Circumetrics helps
We help firms that sell into multiple European markets to:
• map EPR obligations across jurisdictions,
• compare PRO offers using consistent metrics,
• set up data flows for reporting, and
• engage with standard setters and regulators.
If you need a short diagnostic for your EPR exposure we can produce a two page summary with action points you can use internally or share with your board.
What next for EPR?
Standards and regulation are converging. The PPWR sets a new legal baseline with a timeline of mandatory measures that will transform the packaging we use commencing from 2026. A BSI standard for PRO operation could make compliance simpler and fairer. If you want to reduce surprise costs and make your compliance predictable, start by cleaning your data and asking PROs for clarity.
If you would like to talk more about EPR exposure or check your responsibilities, contacts us via our Connect with us form, or contact Mark Sayers via LinkedIn.