S P E C I A L F E AT U R E O N E X T E N D E D P R O D U C E R R E S P O N S I B I L I T Y

Producer Responsibility Organizations

Development and Operations
A Case Study
Kieren Mayers and Scott Butler

Keywords:
Summary
extended producer responsibility (EPR)
industrial ecology Extended producer responsibility (EPR) regulations are now in effect in 27 European Union
producer responsibility organization (PRO) member states and are applicable to up to 100 million tonnes of waste packaging, batteries,
recycling automobiles, and electrical and electronic products annually. This article investigates the
waste management implementation of EPR through a case study of European Recycling Platform (ERP) UK Ltd.,
waste electrical and electronic equipment
the UK arm of one of the largest producer responsibility organizations (PROs) in Europe,
(WEEE)
recycling more than 1.5 million tonnes of waste electrical and electronic equipment to date.
Previous research is extremely limited on the detailed operations of PROs. This case is pre-
sented as an example illustrating typical operational challenges PROs face in implementing
EPR, such as how PROs gain an understanding of the waste management infrastructure and
legislation in each country, collect sufficient volumes of waste using cost-effective arrange-
ments, and maintain uninterrupted collection, treatment, and recycling services. The case
study provides new insights and context on the practical implementation of EPR regulations
relevant for both policy makers and researchers.

Introduction Although EPR legislation aims to improve standards of waste

treatment and recycling, and also increase the overall quantities
European Union (EU) legislation now requires producers1
of waste recycled, its main purpose is to provide producers with
to organize and finance the collection and recycling of their
incentives to develop products that are easier to treat and re-
products at end of life. Extended producer responsibility (EPR)
cycle at end of life (Lifset 1993; Lindhqvist and Lidgren 1990;
regulations have been imposed across 27 EU member states2 ap-
Turner and Pearce 1993). Examples can be found indicating
plicable to batteries (2006/66/EC), automobiles (2000/53/EC),
that such incentives do exist for packaging (Mayers 2007), as
packaging (94/62/EC),3 and waste electrical and electronic
well as for automotive, electrical, and electronic products in
equipment (WEEE) (2002/96/EC).4 Following recent multi-
Sweden and Japan (Tojo 2004).
party government debates (termed “Grenelle de l’ Environ-
Recognizing the importance of encouraging the develop-
nement”), EPR may also be introduced in France for medical,
ment of products that are easier to treat and recycle at end of
furniture, household hazardous, and construction wastes (ENDS
life, the WEEE Directive, Article 8.2, explicitly states that each
Europe 2008).
producer must be responsible for financing the waste manage-
This research details some of the operational challenges and
ment costs of their own products sold from August 2005 onward.
aspects of EPR implementation within the EU from the per-
This requirement, known as individual producer responsibil-
spective of a producer responsibility organization (PRO). Very
ity, is an important clarification to EPR. This concept origi-
little research has been undertaken on this specific subject to
nated from a group of producers, called the Electronics Coali-
date, and this case study aims to illustrate typical challenges in
tion, lobbying on the formulation of the WEEE Directive in
EPR implementation.
2000.

Address correspondence to: Kieren Mayers, INSEAD Social Innovation Centre, European Campus, Boulevard de Constance, 77305 Fontainebleau, France. Email:
Kieren_Mayers@scee.net

© 2013 by Yale University

DOI: 10.1111/jiec.12021

Volume 17, Number 2

www.wileyonlinelibrary.com/journal/jie Journal of Industrial Ecology 277

 A P P L I C AT I O N S A N D I M P L E M E N TAT I O N

Table 1 Numbers of producers and extent of collection required under extended producer responsibility in the European Union (EU)

Number of Number of collection organizations

Product type producers or collection points Type of collection network

Waste electrical and 31,200a 1,303 (municipal authorities Number of local authoritiesb (NUTS [nomenclature of
electronic equipment not collection points) territorial units for statistics] classification level 3: with
population between 150,000 and 800,000 people)
Packaging 130,000 208,000,000c Households
Batteries 1,186 140,000d Retail, schools, offices, and local authority collection points
Automobiles 66 8,002 Authorized treatment centers

Notes: WEEE and packaging numbers of producers are derived from scheme data and will contain national offices of the same company. Battery and
automobile data are by manufacturer and not by number of scheme registrations. This is the inherent difficulty in defining “a producer.” In this case the
data represent the administrative level of organizations of each producer versus each collector.
a Members of the Waste Electrical and Electronic Equipment (WEEE) forum (17,000 members) and European Recycling Platform (ERP; 1,300 members)

add up to 18,300 members. The ERP and WEEE Forum producer responsibility organizations account for about half of the WEEE recycled in Europe (at
1.5 and 0.26 million tonnes, respectively, compared to 3 million tonnes of WEEE overall [WEEE Forum 2009]): 18,300/1.76 × 3.00 = 31,200 estimated
producers within the EU.
b WEEE is also collected from retail outlets in many countries, but data are not available on the quantity.
c The EU population in 2009 was 499,747,211, with 2.4 people per household: 499,747,211/2.4 = 208,228,004.
d Estimated based on the frequency of 3,400 people per collection point (based on European Recycling Platform UK experience).

Sources: Energy Sourceguides 2009; European Commission 2007; European Parliament 2008; Eurostat 2009a, 2009b; Parkers 2009; Pro Europe 2007; Shao
and Lee 2009; Walls 2006; WEEE Forum 2009.

Unfortunately individual producer responsibility for WEEE r single national schemes,

has not been implemented by the EU member states (Castell
et al. 2004; Lindhqvist and Lifset 2003; Sander et al. 2007),
and the WEEE legislation does not define producers’ financial
responsibilities specifically enough to create such incentives
(Mayers 2007). Current approaches are either limited due to
cost or do not go far enough in allocating the actual costs of
different products to each producer (INSEAD 2010). There-
fore PROs established to-date allocate costs to producers on a
collective basis.
The introduction of EPR is complex: many thousands of
producers and waste collectors must find systematic methods
of working together to ensure waste is collected where and
when required (table 1). PROs are consequently used to man-
age waste services and administer multiple payments to finance
these operations. This recent development is noteworthy: be-
tween 1998 and 2007 it has been estimated that at least 260
PROs were established in Europe (Mayers 2007).
PROs are usually responsible for organizing the collection
of waste from designated public and retailer collection points,
providing treatment and recycling, and reporting results to na-
tional governments (figure 1):
r Recycling, logistics, and waste companies subcontracted
by PROs carry out day-to-day operations.
r PROs recover their costs from producers either through
fixed fees or variable cost sharing between producers based
on the quantity of products sold.
r Producers ultimately recover their take-back costs from
their customers, either as part of normal product pricing or
visible recycling levies charged on top (Clift and France
2006).5
PROs may operate in various contexts (Mayers 2007) as, for
example,
r industry sector schemes,
r multiple competing schemes within a country or sector,
or
r multinational schemes.
Whatever the particular setup of the PRO, it must ulti-
mately collect a sufficient quantity or proportion of waste to
meet the combined obligations of its member producers (based
on the quantity of products they sell). As an added complex-
ity, countries with competing schemes must establish common
agreements or frameworks to allocate waste collection responsi-
bilities equitably between different PROs. In the United King-
dom, the Environment Agency is responsible for registering
PROs and ensuring they meet annual collection targets for
packaging, batteries, and WEEE (EA 2011). In Portugal and
Ireland, each PRO’s plans for WEEE collection must be ap-
proved and monitored as part of their formal government au-
thorization (WEEE Register Society 2013). National clearing-
house bodies, responsible for allocating the pickup of WEEE
from each municipal collection site to individual PROs, have
also been established in Austria, Germany, Italy, Spain, and
Denmark (e.g., see OFIRAEE 2012).
The scale of changes introduced under EPR legislation is
significant: in 2006 almost 100 million tonnes of postconsumer
waste were subject to recycling under EPR (table 2), compared
with the EU’s 258 million tonnes of municipal waste (Eu-
rostat 2006b).6 For example, 51 of an estimated 129 PROs
for WEEE have reported they recycled 1.76 million tonnes
of WEEE in 2008, with a turnover of 184 million euros (€)
(Mayers 2007; Shao and Lee 2009; WEEE Forum 2009).7 Re-
search detailing the development and operations of PROs is
limited. For example, a case study has been undertaken into
the strategy and setup of the European Recycling Platform SAS

278 Journal of Industrial Ecology

 S P E C I A L F E AT U R E O N E X T E N D E D P R O D U C E R R E S P O N S I B I L I T Y
Figure 1 The role of producer responsibility organizations.
Table 2 Total potential waste within extended producer responsi-
bility in the European Union (EU) in 2006
Waste category EU waste in 2006 (tonnes)
Packaging 81,300,000
WEEE 7,390,000
End-of-life vehicles 8,000,000–9,000,000
Batteries 1,610,000
Total 99,300,000
Notes: WEEE = waste electrical and electronic equipment.
Sources: Eurostat 2006a, 2006c, 2006d.
PRO (Shao and Lee 2009), and annual reports are published
by the WEEE Forum with data on the performance of member
PROs (WEEE Forum 2009), but there appears to be little else
available.
Overall the introduction of EPR legislation changes the
primary customer’s contracting recycling services from local
authorities to producers. Collection and recycling services, orig-
inally contracted regionally for several types of waste, are in-
stead contracted for specific types of waste on a multiregional,
national, or even international basis. The impact and scale of
these changes do not appear to have been subject to much in-
depth research or analysis, possibly due to problems accessing
and publishing information and business plans proprietary to
recycling companies. To gain some further insight, a case study
of the European Recycling Platform United Kingdom Limited
Mayers and Butler, Producer Responsibility Organizations Development and Operations
(ERP UK Ltd.) is used herein to illustrate some of the actual
commercial, operational, and supply-chain management chal-
lenges involved.
Case Study Introduction
European Recycling Platform (ERP) is a PRO providing bat-
tery and waste electrical and electronic collection, treatment,
and recycling services to more than 1,800 member producers
within the EU. Headquartered in Paris, and established in 2002,
ERP now operates 23 different PRO schemes for WEEE and bat-
teries in 12 European countries, with a global turnover of €88
million in 2010. ERP has recycled 1.5 million tonnes of WEEE
and 11.6 million kilograms (kg) of batteries since its inception,8
and is now responsible for treating and recycling 15% to 20%
of WEEE and 30% to 40% of waste batteries arising within
each country. Under ERP’s procurement model (and as is nor-
mal for PROs), all physical collection, treatment, and recycling
activities are outsourced to third-party waste management com-
panies.
ERP started its recycling of WEEE in the United Kingdom
(the focus of this case study) in July 2007 and now collects
around 15% of the total nationally from approximately 400
municipal collection points (amounting to 89,000 tonnes in
2009). ERP UK’s waste battery collection and recycling oper-
ations were established in 2009, covering 26% of waste batter-
ies collected through approximately 5,000 smaller retailer and
school collection points.
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The case of ERP UK provides a unique opportunity for
insight: it is part of one of the largest contractors of WEEE
recycling services in Europe, information on its setup could be
readily collated first hand by the author (see the About the Au-
thors notes at the end of this article for more details), and the
company is arguably one of very few experienced and able to
respond to EPR in multiple countries. The study provides an
overview of how ERP UK manages and administers its activities
and how it designs, builds, and operates its collection and recy-
cling services at various stages. The findings of the case study
are then discussed further in relation to wider issues of defining
a producer’s responsibility under EPR, issues of conflict between
collectors and producers regarding ownership of waste, admin-
istration and allocation of costs by PROs, and inconsistencies
between EPR requirements in different countries.
Management and Administration
A notable proportion of a PRO’s expenditure is used to em-
ploy management, expert, and administrative staff to organize
its activities. For WEEE, such overheads can add up to 20%
of PRO expenditures (WEEE Forum 2009)—on average, ERP
overheads are 8%.
In total, 13 full-time-equivalent (FTE) employees are based
in ERP UK’s national offices to promote membership relations,
ensure ERP is compliant with its license conditions, ensure
efficient and continuous local operations, and manage admin-
istration of invoicing to members as well as companies used for
collection and recycling:
r a general manager responsible for overall direction and
leadership;
r a technical specialist responsible for investigating new ar-
eas and supporting detailed planning and implementation
of new activities and processes;
r a business development manager to oversee relations
with retailers and municipalities responsible for collec-
tion points;
r a supplier relationship manager to conduct tenders for
waste management services and oversee relationships
with suppliers;
r an operations manager supported by three regional ac-
count managers assigned to carry out audits, manage the
various appointed suppliers and collection points on a
day-to-day basis, and ensure operations run reliably; and
r a team of two administrators responsible for receiving
and responding to requests for collection and recycling,
and two administrators responsible for invoicing and pay-
ments between suppliers and producers.
To date, many of these roles and tasks have been outsourced
by ERP UK to a general contractor operating on their behalf,
but as of the summer of 2011 their tasks and roles have been
integrated and recruited directly within the PRO. This article
focuses on how these tasks have been organized, not the partic-
ular contractual arrangements involved, and ERP UK refers to
280 Journal of Industrial Ecology
all directly managed and outsourced functions of the ERP PRO
within the United Kingdom.
Consolidation and centralization of additional specialist pro-
curement, finance, and communications functions in ERP’s
head office in Paris provides additional support, avoids repli-
cation within each individual country, enables the company’s
combined experience to be shared between countries where
ERP operates, and allows administrative processes to be stan-
dardized where advantageous. Interestingly, it has been reported
that this is one reason ERP is competitive compared with other
national PROs despite operating on a multinational basis (Shao
and Lee 2009).
Establishing and Organizing Extended
Producer Responsibility Activities
Generally there are three phases to setting up and organizing
PRO collection, treatment, and recycling services, which can
be broadly referred to as design, build, and operate.
Design Phase
During the design phase PROs must investigate and define
a number of details important to planning and setting up col-
lection, treatment, and recycling processes within a country (as
was the case with ERP UK), including
r understanding regulatory requirements,
r defining and establishing the collection network needed
r
to match a PRO’s estimated market share,
determining conditions required to access waste at col-
r
lection points,
evaluating the available recycling services and prices, and
r preparing plans and input for PRO license applications.
Building Phase
After completing their detailed business development plans,
PROs (including ERP UK) must establish collection, treatment,
and recycling processes during the build phase of their work,
which involves
r determining collection arrangements and containers;
r auditing recycling and treatment companies to ensure
compliance with applicable legislation as well as mini-
mum standards required by producers;
r selecting and appointing collection, treatment, and recy-
cling companies; and
r implementing and adjusting management and adminis-
trative procedures.
Operating Phase
Once all planning and arrangements are complete, PROs
then enter their operating phase, during which a number of key
activities must be managed and maintained, including
 S P E C I A L F E AT U R E O N E X T E N D E D P R O D U C E R R E S P O N S I B I L I T Y
r ensuring requests for collection and recycling are received
and responded to;
r collating and submitting reports of quantities collected
and processed;
r accounting and payment for collection, recycling, and
treatment services;
r troubleshooting operational and service-related issues and
problems; and
r optimizing overall activities to meet key performance
indicators.
Although the design and build phases occur before the start
of EPR obligations within a country, there is often repetition
and overlap of these stages as new suppliers or collection points
are taken on after the operating stage has already begun. Each
stage is described in further detail below, using ERP UK as the
case study example.
Designing Collection, Treatment,
and Recycling Services
One of ERP UK’s main responsibilities is to collect a suffi-
cient quantity of waste from local authority and retailer waste
collection points to cover their aggregated producer members’
obligations at a cost low enough to sustain competitive pric-
ing compared to other PROs. ERP UK’s initial planning took
about 70 FTE days of specialists’ time to develop the necessary
implementation plans.
Understanding Regulatory Requirements
As part of the initial planning, ERP UK investigated any
national regulatory requirements differing from requirements
in the WEEE Directive impacting their operations, including
those stipulated as part of their PRO licensing conditions. Such
issues affect all PROs, and licensing conditions can varying
between countries, such as those
r only allowing use of local recyclers (as is the case in
Spain);
r specifying the type of containers used in collection (such
as in Germany and also proposed in Spain as of 2009);
r requiring approval of fixed PRO prices to producers (such
as in Ireland and Portugal);
r following different regional rules (such as in Spain, which
has 17 different regional WEEE implementations); and
r requiring collection planning to be coordinated through
bodies or agreements for allocating collection responsi-
bilities to PROs (such as in Germany and Italy, where
national clearinghouses have been set up, and in Ireland,
Portugal, Austria, and France, where PROs negotiate and
come to agreement together on the allocation of collec-
tion responsibilities).
Mayers and Butler, Producer Responsibility Organizations Development and Operations
Figure 2 European Recycling Platform United Kingdom waste
electrical and electronic equipment (WEEE) collection population
coverage in 2007.
Definition of the Collection Network Needed
As with all PROs, ERP UK must sign agreements with a
sufficient proportion of collection points (share of collection
sites and waste arising each year) to ensure enough waste is col-
lected to cover each producer member’s responsibilities (pro-
ducer share as a proportion of weight of products put on the
market each year).
Under- and overcollection is common between PROs, which
must find ways to compensate one another from year to year. Ar-
bitration can become highly problematic in countries where this
balancing is left to negotiation and trading between schemes:
PROs can deliberately overcollect and charge high prices to
other PROs in locations where they are forced to balance with
one another (as in the UK; ENDS Report 2008: 23), or under-
collect and charge lower prices to producers in countries where
they are not (as in France, where negotiations to balance WEEE
collection responsibilities between PROs lasted from 2007 until
2009).
Determining Conditions Required to Access Waste at
Collection Points
A PRO’s ability to obtain waste is critically important: with-
out waste a PRO cannot operate. ERP UK found that the rate
of take-up of their services by collection site operators declined
exponentially over time (figure 2). Even in countries where
collection responsibilities are allocated by clearinghouses or
agreements between PROs, negotiations with local authorities
to establish collection arrangements require some time. ERP
UK’s commercial/business development manager spends up to
a quarter of his/her time securing and/or establishing the top
four or five collection accounts supplying 80% to 90% of their
collected volume, but the remaining time is spent on smaller
sites to reach the 100% of the PRO’s obligations.
If local authorities are not satisfied with arrangements they
may either select another PRO to work with or may complain
to governing bodies that the PROs do not provide sufficient or
satisfactory services. In summary, local authorities are customers
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of PRO services and exert commercial and political pressure on
PROs to address their specific needs and concerns. This means
that PROs must enter into a dialogue with them and manage
an ongoing commercial relationship, not only with each local
authority, but with each individual collection point requiring
pickup of WEEE. The United Kingdom has adopted a code of
practice recognizing the importance of and guiding relations be-
tween designated collection facilities and PROs (Environment
Agency 2012).
In ERP UK’s experience within the UK, where local author-
ities and retailers may choose their preferred PROs, they make
their selection based on the perceived reliability of their col-
lection services, the impressions of existing or past customers
through written references, the quality of the collection con-
tainers provided, access to local staff attentive to their specific
needs and requests, and value-added features such as support
of reuse, support for local communications such as leaflets and
onsite signage, expert help and workshops, etc. In some cases
collectors may even ask PROs for payment for surrendering
their wastes (or contributions to onsite sorting costs), which
exerts inflationary pressure on PRO prices. For example, PROs
are required to pay €35 and €60 per tonne of waste collected
to contribute to municipal sorting costs in Portugal and France,
respectively.
Even where collection is agreed on with collection sites, not
all waste may be made available to PROs, particularly where
it has a net value, such as with waste automotive batteries,9
automobiles (Fergusson 2009: 57–58), and WEEE, especially
monitors, televisions, and large domestic appliances (Huisman
et al. 2007: iv). In spite of any legal requirements to the con-
trary, such wastes typically will disappear from collection points
or recycling facilities before PROs or producers are able to col-
lect them. For example, it can be approximated that about 67%
of the 7.39 million tonnes of the estimated household WEEE
arising in Europe in 2008 remains unaccounted for (European
Commission 2008), much of which was most likely diverted
along unreported and undisclosed routes involving reuse and
materials recovery overseas, often in poor working and envi-
ronmental conditions (Greenpeace 2009).
PROs, therefore, must deal with a difficult disconnect be-
tween the aim of EPR, which expects producers to accept re-
sponsibility for physically collecting, treating, and recycling
WEEE, and the fact that producers do not actually own or
posses title to their end-of-life products. On the other hand,
any expectation of authorities to be compensated for their loss
of WEEE revenue contradicts the principle of EPR: those pro-
ducers with products that are easy to recycle and with net
value would find themselves penalized simply by having to
buy their products back. This hardly encourages design for
recycling, and is a limitation of EPR as implemented within
the EU.
Evaluating the Available Recycling Services and Prices
Naturally producers want to know prices before agreeing
to join a PRO at the start of EPR obligations. This is almost
282 Journal of Industrial Ecology
impossible to gauge for PROs: ERP UK found it took about
3 years for waste management prices to reach an equilibrium
following the introduction of the national WEEE regulation.
Waste collection and recycling companies, usually used to work-
ing under local authority contracts, are not necessarily used
to working with new PROs operating nationally, and initial
prices quoted may either be underpriced, aimed at winning
new business in highly competitive markets, or overpriced, in
markets that previously were not operating competitively. For
example, when three new competing PROs established ser-
vices for small appliances in Austria during the third quarter
of 2005, the existing PRO scheme lowered its prices by more
than 50%, and by the first quarter of 2007 the cheapest of these
PROs had lowered their price by almost 90% compared to the
schemes original price (Shao and Lee 2009). Also, initial uncer-
tainty about quantities collected leads to uncertainty about final
costs.
To research market conditions in each country, ERP UK
has a specialist procurement manager, who visited collectors
and recyclers a few years before operations began. At the time
of writing this included about 70 different waste management
companies. Depending on the specific network of collection
points and recyclers, ERP UK found collection and recycling
prices fell by about one-third (on average) following optimiza-
tion over its first 2 to 3 years of operation.
Preparing Plans and Input for Producer Responsibility
Organization License Applications
Before a PRO can begin operations it must submit license
applications, including detailed organizational and operational
plans (ERP UK must comply with licensing conditions gov-
erned under S.I. no. 3289 – 2006: Part 4). PROs usually must
specify details such as collection points and how they will be
managed, the quantities of waste expected, which recycling
companies will be used, how collections will be organized, how
reporting of collected volumes will be made, target prices for
producers, and so on. A PRO’s business plans must be particu-
larly detailed, accurate, and convincing, as they are ultimately
subject to review by regulators.
Building Collection, Treatment, and
Recycling Services
Once planning was completed in June 2007, ERP UK started
to put their arrangements and procedures for collection, treat-
ment, and recycling into effect. Suitable collection containers
and vehicles had to be determined for each collection point,
recycling companies had to be audited and appointed, and op-
erators had to be informed and trained on new operational,
administration, and reporting procedures.
Determining Collection Arrangements and Containers
To organize collection and recycling services effectively,
it is very important for PROs, which usually outsource waste
 S P E C I A L F E AT U R E O N E X T E N D E D P R O D U C E R R E S P O N S I B I L I T Y
management services and do not own their own transporta-
tion or waste processing facilities, to understand the features of
the local waste management infrastructure. To achieve the best
economy of scale, operations ideally need to be as standardized
as possible, employing the same vehicles and container types as
far as is possible.
Where some sites may accommodate a large container and
be open 7 days per week, others may be small and have re-
stricted opening hours. In total, ERP UK organizes waste col-
lection from about 400 municipal collection points across the
United Kingdom (and additionally about 5,000 retail, school,
office, and other types of collection points for batteries). Re-
gional account managers undertake diagnostic exercises before
operations start, visiting each site and recording details neces-
sary to determine the appropriate collection arrangements. ERP
UK uses a number of flexible strategies to ensure producer and
collector requirements and expectations can be met, such as
r using local collection companies with a detailed under-
standing of the most cost-effective means of collection
within a specific region;
r winning collection contracts with regions close to large
cities, which tend to have sizeable and affluent popula-
tions, large quantities of WEEE, well-equipped and size-
able collection points, and good access for transport with
generally less traffic congestion; and
r providing each collection point with a degree of choice,
local procurement managers and regional account man-
agers investigate and present a range of different collec-
tion and container options affordable within their budget
and available from service providers operating in their
locality.
Auditing Recycling and Treatment Companies Against
Minimum Standards
The four founders of ERP (Sony, Braun-Gillette, Electrolux,
and HP) have defined common audit requirements to ensure
all suppliers comply with environmental, waste, and other leg-
islation and adopt sufficient standards of operation. These re-
quirements have now been combined and enhanced to form
ERP’s supplier audit framework. Municipalities may also ask to
have copies of audit reports to demonstrate “duty of care” for
waste materials originating from their collection points. To en-
sure all suppliers comply with environmental, waste, and other
legislation, and that they adopt sufficient standards of oper-
ation, ERP UK arranges audits of all recycling facilities used
to service its treatment requirements (with detailed technical
audits being repeated at least every 3 years). Although only
a small proportion of suppliers may fail the audit each year,
the audits also help in the development of improvement ac-
tions, such as raising the standard of record keeping on the
input-output balance of waste materials at recycling facili-
ties (while perhaps interesting, further details are proprietary
to ERP).
Mayers and Butler, Producer Responsibility Organizations Development and Operations
Selecting and Appointing Collection, Treatment, and
Recycling Companies
Once a collection network has been established, ERP
UK’s procurement manager reviews and reallocates contracts
to ensure competitive pricing and use of the best technolo-
gies. For example, regions may be opened up for competitive
tender on a national basis, and tenders can be opened to
new and smaller local players or service providers with new
technologies.
Implementing and Adjusting Management and
Administrative Procedures
Finally, operators at collection points need to understand
how to segregate waste into categories with similar treat-
ment requirements, including large domestic appliances (LDA),
cooling equipment (COLD), televisions and monitors (DIS-
PLAYS), mixed WEEE (MIXED), lighting (LAMPS), portable
batteries (DISPOSABLE BATTERIES), and automotive and
industrial batteries (LEAD-ACID BATTERIES). They also
need to know who to contact and what to do to request col-
lection, report any unexpected problems, or establish a routine
schedule of pickups. ERP UK’s regional account managers or-
ganize both formal training (using presentations) as well as
informal training (site walk-arounds) and provision of commu-
nications materials (contact cards and separation guides) for
collection site operators.
Operating Collection, Treatment, and
Recycling Services
Once planning and implementation were completed, ERP
UK finally started its collection and recycling operations in July
2007.
Receiving and Responding to Requests for Collection
and Recycling
ERP UK must ensure that requests to either arrange collec-
tion or change collection schedules are managed from the 400
or so collection points for which it is responsible. At the time
of writing, two FTE operations staff were employed centrally in
London to receive these requests by telephone, fax, and email,
working to suit the operating hours within each collection site,
and then liaise with collection and recycling companies to en-
sure WEEE collections are scheduled and conducted according
to plan. Each collection order is logged and filed with orders
for recycling, weighbridge tickets, destruction certificates, and
evidence of recycling.
Collating and Submitting Reports of Quantities
Collected and Processed
One of the services PROs provide for producers is accurate
and timely reporting on tonnages collected and recycled. It is
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important for PROs to develop and maintain precise but flexible
information systems to these ends. Without a clearly traceable
documentation trail, producers and PROs do not have the evi-
dence they need to prove that they have complied with obliga-
tions under EPR legislation. Municipalities also need accurate
data for reporting tonnes of waste collected and recycled from
their collection points.
As increasing numbers of PROs attempt to harmonize the
way waste and recycling companies report data to them—
primarily to streamline their administration—waste and re-
cycling companies are increasingly faced with many differ-
ent reporting requirements. As a consequence, there may of-
ten be weeks or months of delay between the collection
and final reconciliation of recycling figures. At the time
of writing, ERP was implementing a new bespoke informa-
tion technology (IT) system, developed by ERP’s head of-
fice in Paris, in an attempt to improve the handling and
efficiency of this data flow and minimize data handling
errors.
Accounting and Payment for Collection, Recycling,
and Treatment Services
PROs that set a fixed fee per unit or mass of product
or packaging sold can guarantee, to a degree, that a vol-
ume of cash is always incoming to offset charges from collec-
tion and recycling companies; however, PROs in the United
Kingdom follow a pay-as-you-go financing system, where pro-
ducers only pay for waste collected; therefore monthly re-
porting and administration need to be carefully managed
(figure 3):
r Collection phase: at the end of each month recyclers
prepare reports on the tonnages they have processed.
r Reporting phase: once these reports have been re-
ceived, ERP UK divides the costs in relation to
each producer’s market share and then invoices its
members.
r Payment phase: producers pay ERP UK’s invoices against
standard payment terms and then ERP UK pays its sup-
plier’s invoices.
Overall the additional complexity of waste management ac-
counting under EPR can result in increased financial pressure
on recycling companies compared with that under municipal
responsibility.
Troubleshooting Operational and Service-Related
Issues and Problems
Collection and recycling rarely run without incident. Re-
cycling plants can catch fire or close due to bankruptcy, and
whole counties and regions then need to be reallocated to al-
ternative recyclers to maintain local collection services. If col-
lections cannot be undertaken, a backlog of waste at collection
points can quickly occur, and householders may have to be
284 Journal of Industrial Ecology
turned away at the gates. ERP UK’s operations manager and a
team of three regional account managers investigate and ensure
collection, treatment, and recycling run with a minimum of
interruptions.
Collection site operators may also fail to store WEEE on-site
properly, creating health and safety hazards and unreasonable
and unplanned delays in loading trucks. Figure 4 shows an ex-
ample of bad storage of LDA at a municipal collection point.
PROs must plan for troubleshooting of such unexpected prob-
lems, such as by organizing training and on-site inspections.
Figure 4 also shows an example of improved storage of LDA
following several meetings and inspections with a local ERP
regional account manager.
Optimizing Overall Activities to Meet Cost and Key
Performance Indicators
Waste collection, treatment, and recycling services contin-
ually evolve as new technologies are developed, as companies
enter the market, and as new services become available in differ-
ent geographic regions within a country. ERP UK must ensure
their performance is continuously improved to meet expec-
tations of members and remain competitive, and so it uses a
number of defined key performance indicators (KPIs) on price
benchmarking, tonnages collected per collection (to ensure op-
timum vehicle and container utilization), recycling efficien-
cies, and other such factors (specific details of these KPIs are
confidential).
ERP UK continually works on selected reviews and projects
in an effort to improve efficiency and performance. Such ac-
tivities are important if any PRO is to remain competitive and
effective in the long term.
Discussion: Key Problems in
Implementing Extended Producer
Responsibility
PROs set up by producers purely for the job of take-
back compliance are at a natural disadvantage relative to
waste management companies already operating waste man-
agement services at or from collection points. Many producers
choose to invest in industry-led recycling schemes to ensure
that in the long term PROs act in their interest to opti-
mize processes and costs, as is the case with ERP (Korfmacher
2003).
This case study of ERP UK provides an example of how
PRO services can be established and operated, and highlights a
number of important practical aspects of EPR implementation.
As illustrated above, PROs must be able to cope with a number
of challenges, such as maintaining sufficient cash flow despite
financial uncertainty, managing the substantial administration
and number of transactions cost effectively, verifying data and
reporting, securing collection agreements with waste collection
sites, and maintaining specialist expertise on EPR setup and
operation.
 S P E C I A L F E AT U R E O N E X T E N D E D P R O D U C E R R E S P O N S I B I L I T Y

Figure 3 Example reporting and payment cycle for pay-as-you-go producer responsibility organizations.

Figure 4 Storage of large appliances before and after training.

PRO activities are required uniquely to support EPR regula-
tions, which require thousands of producers to find ways to work
efficiently with thousands of collectors. As well as providing an
example of PRO operations under EPR, this case study details
a number of practical areas of implementation, unanticipated
by policy makers and researchers before the implementation of
WEEE regulations in Europe, that appear counterproductive to
the aims of EPR (table 3).
As a result of EU WEEE Directive amendment discussions
that were under way at the time of writing, producers may
be required to provide financial compensation to collectors to
prevent WEEE from being shipped overseas. Contrary to the
aims of EPR, this would penalize producers with products that
are easy and valuable to recycle at end of life, which are more
likely to be diverted from PROs. This should be considered
carefully in setting collection targets for WEEE; not all WEEE
will be collected under EPR regulations.

Under Extended Producer Responsibility Producers Are

Responsible for Waste, But Do Not Own It
As explained in the section on Design, PROs must determine
the conditions required to access WEEE at collection points.
The WEEE Directive is neither sufficient, nor sufficiently en-
forced, to prevent waste with a positive value being diverted
at collection points. Collectors still retain legal title and rights
of ownership over any waste they collect. This can be counter-
productive to EPR: producers selling products that are easy to
recycle (and therefore more profitable to recycle) at end of life
are liable to “lose” them. This also creates instability for recy-
cling service providers working with PROs, as materials they
are depending on to maintain prices may suddenly be diverted
away.
Extended Producer Responsibility
Creates Conflicts Between Collection
and Producer Compliance
The market for EPR services is complex: it is not a simple
process of supply and demand between customers and suppli-
ers driven by a single price (figure 5). Municipalities, retailers,
producers, and materials producers are all influential yet in-
dependent users of PRO and recycling services, and can have
conflicting demands regarding the same waste collection and
recycling service. Unfortunately, if left to their own devices
under EPR, producers and collectors are fundamentally in con-
flict: producers seek EPR compliance from PROs at competi-
tive prices, whereas collection points seek the best and most

Mayers and Butler, Producer Responsibility Organizations Development and Operations 285
 A P P L I C AT I O N S A N D I M P L E M E N TAT I O N

Table 3 Issues arising from the implementation of extended producer responsibility (EPR)

EPR requirement Issue Consequence Solution

Producers are responsible Producers do not own
for waste waste
Producers must organize Balancing of collected
collection volumes with producer
obligations does not
arise automatically
from market forces
Producers organize Requires careful
collection from administration of waste
municipalities and and sales reporting, and
retailers also cost allocation and
invoicing
European Union member PROs and multinational
states may implement producers must find
differing national solutions country by
legislation country
Notes: PRO = producer responsibility organization; WEEE = waste electrical and electronic equipment.
Waste with value is likely
to be lost to EPR
PROs can deliberately
under- or overcollect to
gain financial
advantage
Calculating and allocating
costs to producers has
associated
administrations costs,
but incentives for
design changes are
missing
EPR implementation
tends to focus on
national collection and
pretreatment, not on
the whole reuse and
recycling chain
EPR targets must take
account of waste not
captured under EPR
Governments must
intervene to ensure
PROs balance their
obligations equitably
PROs may develop new
and improved methods
of cost allocation in the
future
Harmonization of WEEE
categorization and
reporting, and
treatment standards
may help improve
overall reuse and
recycling

effective (and, by extension, often the most expensive) col-
lection services. An issue highlighted in the case study that
PROs must consider in the design of their strategy and plans
for collection is how to gain agreement with municipalities or
retailers in such situations. Ultimately both PROs and collec-
tion points will strive for greater efficiency, and the success of
any PRO will depend on how successfully it can broker its ser-
vices to collection points and intermediate waste management
companies.
A major problem with EU EPR directives is that they do
not address how collection obligations should be balanced be-
tween PROs, which consequently must be addressed by mem-
ber states in their national implementation. Enforcement au-
thorities must intervene to make sure PROs do not delib-
erately over- or undercollect as a strategy to gain a greater
market share of producers versus collectors with WEEE (or
vice versa). Otherwise, experience has already demonstrated
that EPR legislation can fail to prevent inappropriate behav-
iors: as explained above, PROs can deliberately undercollect
and be rewarded with lower costs, or they can overcollect
and raise the price of their excess tonnages when balanc-
ing with competitors. Enforcement or coordinating authori-
ties can ensure a level playing field and that producers and
PROs are not unjustly and unintentionally rewarded for such
behavior.
Unfortunately the current WEEE Directive revisions do not
address this matter. Therefore member states have all taken
different approaches and degrees of intervention, leading to a
further lack of harmonization within the EU.
Extended Producer Responsibility
Administration and Cost Allocation
Must Be Carefully Managed
Although establishing and operating PROs involves addi-
tional administration compared to municipal waste manage-
ment, they bring improved economies of scale, process control,
and increased recycling levels. These are certainly important
aims of EPR. However, similar results could also be achieved
by setting up national procurement of recycling services by mu-
nicipalities. As discussed above, a proportion of PRO costs are
caused by accounting and allocating costs to producers. With-
out any direct link between a producer’s products and their
specific end-of-life costs, such additional administrative costs of
producer involvement raise interesting questions on the effec-
tiveness of ERP implementation.
National Requirements Conflict
in Many Areas
As the case study presented here illustrates, in their de-
sign and operation PROs must address many different national
requirements concerning their licensing conditions, adminis-
tration, logistical arrangements, and recycling and treatment
requirements. Increased harmonization of such requirements
would help to improve competition within the EU and reduce
administrative overheads for PROs that otherwise must employ
specialists with knowledge within each country. The revision
of the WEEE Directive will potentially try to harmonize WEEE

286 Journal of Industrial Ecology

 S P E C I A L F E AT U R E O N E X T E N D E D P R O D U C E R R E S P O N S I B I L I T Y
Figure 5 The influence of different stakeholders in the market for extended producer responsibility services.
categorization and reporting within each country, but leaves
the scope of EPR operations for definition by member states.
Inevitably, as materials markets are global, PROs may be
better positioned to ensure improved materials recycling pro-
cesses if national legislation and PRO requirements are better
harmonized.
Conclusions
EPR regulations have been introduced throughout Europe
covering 29 countries and up to 100 million tonnes of waste per
year, and requiring many thousands of producers and collectors
to have to work together to ensure collection and recycling.
By 2007 more than 260 PROs had been established to finance
and organize recycling in Europe for packaging, batteries, and
WEEE.
ERP UK’s main objectives in this role are to gain “access
to waste,” maintain nationwide collection and recycling activ-
ities, and ensure high-quality cost-effective compliance. ERP
UK developed its operations in three stages: design, build, and
operate. This reflects that PROs need first to understand the
existing infrastructure and legislation, then balance collection
requirements with the capabilities of waste companies available
in each region, and finally ensure that collection, treatment, and
recycling operate cost-effectively and continuously.
It is likely that EPR will continue to be adopted worldwide
and to cover new waste streams—for example, in Australia,
Canada, the United States, South America, and central Asian
countries, and covering furniture, medical, construction, and
Mayers and Butler, Producer Responsibility Organizations Development and Operations
household hazardous wastes, as under review since in 2010
in France. EPR policies are likely to be implemented with
increased cost to industry and society. It remains important
for producers, policy makers, nongovernmental organizations
(NGOs), and the research community to continue to evolve
such policies and practices to ensure they ultimately deliver
their main aim: to ensure that producers are rewarded with rel-
atively lower end-of-life costs for products designed to be easier
to recycle at end of life and using fewer and less hazardous ma-
terials. At the same time, and as outlined in this research, EU
member state governments should also take steps to ensure that
PROs operate in an environment without unnecessary mar-
ket failures and conflicts, and where their responsibilities are
clearly defined, balanced, and enforced. At the time of writing,
it seems that the EU has missed an important opportunity to
address these issues in their current review and revisions of the
WEEE Directive, and it is unlikely that they will be resolved
anytime soon.
Acknowledgments
The authors would like to thank Reid Lifset and Luk N.
Van Wassenhowe for their careful reading and feedback on this
article.
Notes
1. In this context producers include both manufacturers and importers
of products within any country.
287
 A P P L I C AT I O N S A N D I M P L E M E N TAT I O N
2. Similar legislation has also been implemented in Norway and
Switzerland.
3. The EU Packaging and Packaging Waste Directive do not actually
implement EPR, but member state national implementing legisla-
tion does.
4. Norway and Switzerland, although not within the EU, have adopted
similar legislation.
5. Except in Japan, where waste disposers must pay for collection and
recycling of selected household appliances.
6. One tonne (t) = 103 kilograms (kg, SI) ≈ 1.102 short tons. One
million tonnes = one megatonne (Mt) = 106 tonnes (t) ≈ 1.102 x
106 short tons.
7. Exchange rate on 15 January 2011: £1.00 (pound) = $1.59 (U.S.
dollar) = €1.18 (euro).
8. These figures are valid at the time of writing in June 2011. One
kilogram (kg, SI) ≈ 2.204 pounds (lb).
9. In ERP UK’s experience, collectors may not surrender automotive
batteries without remuneration for their metals value, therefore
automotive batteries are rarely collected by PROs. As EPR legis-
lation requires producers to only finance and organize treatment
and recycling, producers, perhaps understandably, do not agree to
compensate parties for lost revenue due to changes in regulations
and responsibilities.
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About the Authors
Kieren Mayers was a research affiliate at the Yale Univer-
sity School of Forestry and Environmental Studies at the time
this article was written. He is currently an executive in resi-
dence at the INSEAD Social Innovation Center and head of
technical compliance at Sony Computer Entertainment Eu-
rope in London, UK. Scott Butler is the managing director of
the European Recycling Platform United Kingdom Limited in
London, UK.

Mayers and Butler, Producer Responsibility Organizations Development and Operations 289