Extended Producer Responsibility (ROP)

Extended Producer Responsibility (EPR) is a mechanism under EU law that shifts responsibility for waste management from local governments and consumers to producers. Its goal is to support efficient resource use and advance the circular economy by incentivizing higher-quality collection, recycling, and reuse of materials.

AmCham Poland has been actively working with member companies on the draft Packaging and Packaging Waste Act, which introduces a new Extended Producer Responsibility (EPR/ROP) system.

In early November, AmCham submitted a detailed position paper to the Chancellery of the President of Poland (Minister Karol Rabenda, Advisor Paweł Gruza). In our submission, we emphasized that the current draft:

• significantly limits producers’ influence over how the system operates, despite placing the full financial burden on them;
• over-centralizes financial flows within the National Fund for Environmental Protection and Water Management (NFOŚiGW), without ensuring adequate transparency or safeguards;
• risks creating double financial charges on the same packaging (ROP fee + SUP fee), without guaranteeing real environmental effectiveness.

We asked that these concerns be taken into account should the bill be submitted to the President for signature. Although a fast-tracked legislative process was initially anticipated, the draft has not yet been sent to Parliament.

The position paper is available here.