Environmental consultancy Eunomia Research & Consulting is inviting retailers, producers, and sellers to register their interest in shaping future EU legislation relating to online sales.
Eunomia is carrying out research for the European Commission to consider ways of improving compliance with extended producer responsibility (EPR) obligations and tackling ‘free-riding’ in the case of online sales. Free-riding occurs when producers – either knowingly or unwittingly – avoid some or all of their responsibilities (and the associated costs) under EPR rules stemming from environmental legislation.
EPR is well developed within the EU for waste electrical and electronic items (WEEE), batteries and packaging. Under EPR, producers (typically brands/manufacturers, importers and distributors/retailers) take financial responsibility for the end-of-life management of products and packaging, by collectively contributing to a common fund. Previous Eunomia research for the OECD estimates that 5-10% of sellers of electronic items placed on the market in OECD countries are not registered with EPR schemes. Research by the WEEE Forum also found that for small electronic products on the UK market between 44-88% of producers were unregistered. Online sales are rising sharply such that left unchecked the problem could potentially undermine the validity of the EPR concept.
This research has been commissioned to understand the scale of the existing problem, the causes of this problem, and to develop ideas for solutions in pursuit of a fair and reliable approach to compliance. Research recommendations will inform the European Commission’s work on developing EPR policy and environmental policy more generally, linking up to potential new roles and responsibilities of online marketplaces to be laid out in the forthcoming Digital Services Act and Digital Markets Act.
Current evidence shows that this is particularly a problem with smaller electrical items and batteries, but is also of significance for packaging, and will be of growing significance to other product categories as EPR is rolled out, such as textiles.
Eunomia Consultant Star Molteno said: “This is a great opportunity for producers and others to get a heads up on which environmental policies coming from the European Commission will affect their business operations. Signing up for updates and/or participating in the research will keep organisations informed and give them the opportunity to help shape solutions.
“Existing approaches were not designed with online sales in mind, but rather on the basis that goods are purchased from ‘brick-and-mortar’ stores. Failure to fully account for online purchases leads to issues in the accuracy of reported sales, and thus of the reported recycling rates, and ultimately undermines the application of Extended Producer Responsibility. Current evidence shows that this is particularly a problem with smaller electrical items and batteries, but is also of significance for packaging, and will be of growing significance to other product categories as EPR is rolled out, such as textiles.”
All stakeholders are invited to register for updates, invitations to stakeholder events and the ability to input here: Register before 8 October 2021. Eunomia is also asking stakeholders to send any written evidence or position papers to EPRonlinesales@eunomia.co.uk, particularly any evidence on the scale of the existing problem, insights into the causes of the problem, and ideas for approaches to tackling the issue.
Stakeholders invited to participate include: online sellers and retailers, other retailers (high street etc), compliance support, consumer associations, government agencies, NGOs interested in waste management and consumer rights, producer associations (WEEE, batteries, packaging), PROs (Producer Responsibility Organisations), research and innovation organisations and waste operations).
Producers and retailers of batteries and electrical and electronic equipment (EEE) are also invited to complete a survey on their experience of EPR compliance by 30 September 2021. The results of the survey will help to shape policy development in the area. All data will be analysed collectively and remain anonymous. Click here to view the survey.