Is Packaging EPR a European Invention? A Short History of Producer Responsibility, 1990 to the PPWR

Is Packaging EPR a European Invention?

Extended producer responsibility for packaging has European roots but is not an EU construct. The concept was defined in a 1990 report to the Swedish Ministry of the Environment, a German ordinance of 1991 applied producer responsibility to packaging, and Japan, Korea and British Columbia made packaging producers responsible before EU law required producer responsibility schemes for all packaging.

For brands, importers, converters and distributors told that packaging EPR is Brussels red tape, this article dates the idea on official texts, OECD publications and one dissertation, read on 27 September 2026. Today's obligations are in our guides to producer registration across EU markets and to eco-modulated EPR fees.

Key Facts

• Extended producer responsibility as a defined policy strategy was introduced in a 1990 report to the Swedish Ministry of the Environment, according to the Lund University doctoral dissertation of its author, Thomas Lindhqvist.
• Germany's Packaging Ordinance of 12 June 1991 placed responsibility for the disposal of packaging on manufacturers and distributors, according to a 1998 Bundestag document.
• Japan's Containers and Packaging Recycling Act is Act No. 112 of 16 June 1995, according to the translation published by Japan's Ministry of Justice.
• Directive (EU) 2018/852 required Member States to ensure that extended producer responsibility schemes are established for all packaging by 31 December 2024.
• Regulation (EU) 2025/40 applies to all packaging, regardless of material, whether household, commercial or industrial, under Article 2(1).
• Our dated PPWR referential (baseline reviewed 15 September 2026) confirms the fifth line; the others are read on the linked sources on 27 September 2026.

Where Does the Idea of Producer Responsibility Come From?

The idea of producer responsibility for packaging draws on two texts: the polluter-pays principle, set out in an OECD Council Recommendation adopted on 26 May 1972, and extended producer responsibility, defined as a policy strategy in a 1990 report to the Swedish Ministry of the Environment. The OECD describes extended producer responsibility as consistent with the polluter-pays principle.

The polluter-pays principle is the rule that the polluter should bear the expenses of the pollution prevention and control measures decided by public authorities, under the OECD Recommendation of 26 May 1972. That Recommendation does not mention extended producer responsibility.

Extended producer responsibility is an environmental policy approach in which a producer's responsibility for a product is extended to the post-consumer stage of a product's life cycle, in the definition recalled by the OECD's 2016 guidance, an update of its 2001 Guidance Manual for Governments. That guidance states that extended producer responsibility emerged in a number of OECD countries in the late 1980s, as municipalities faced waste growing in volume and complexity.

In his 2000 doctoral dissertation at Lund University, Thomas Lindhqvist writes that he introduced extended producer responsibility as a defined policy strategy in a 1990 report to the Swedish Ministry of the Environment, written with Karl Lidgren. Sweden has been an EU Member State since 1 January 1995, according to the European Union's country page.

Which Countries Made Packaging Producers Responsible in the 1990s?

In the 1990s, packaging producer responsibility entered national law. Germany's Packaging Ordinance of 12 June 1991 placed the disposal of packaging on manufacturers and distributors, France's decree 92-377 of 1 April 1992 required producers and importers to contribute to or provide for the elimination of their household packaging waste, and Japan's Containers and Packaging Recycling Act dates from 1995.

The Bundestag document 13/10943 of 12 June 1998 states that the 1991 ordinance regulated product responsibility in waste management comprehensively for the first time in Germany. The same document credits the dual system Der Grüne Punkt, the Green Dot, with sending about 25 million tonnes of sales packaging to material recycling from 1993 to 1997.

The French décret n° 92-377 applied from 1 January 1993 to packaging whose final holders are households. The German and French texts both predate Directive 94/62/EC of 20 December 1994, while the UK regulations of 1997 state in their explanatory note that they serve the targets of that Directive. Japan's Ministry of the Environment states that the Act was enforced in April 1997 and extended to other plastic and paper packaging from April 2000.

How Did Packaging EPR Spread Beyond Europe?

Packaging EPR spread beyond Europe through national, state and provincial laws. The OECD's 2016 guidance reported a survey that identified about 400 EPR systems in operation. Nearly three-quarters of those systems were established since 2001, according to the same guidance, which also found EPR schemes spreading in emerging economies in Asia, Africa and South America.

Korea's environment ministry wrote in January 2003 that its Producer Deposit System of 1992 did not place enough recycling responsibility directly on the producers. Japan's Act of 1995, Korea's system of 2003, British Columbia's programme of 2014 and Chile's framework law of 2016 are all older than Directive (EU) 2018/852 of 30 May 2018.

What Did EU Law Add Before the PPWR?

EU law moved from collection systems to mandatory extended producer responsibility in four steps. Directive 94/62/EC of 20 December 1994 required return, collection and recovery systems. Directive 2008/98/EC allowed Member States to introduce extended producer responsibility. Two directives of 30 May 2018 set minimum requirements and required extended producer responsibility schemes for all packaging by 31 December 2024.

1. 1994. Under its original Article 7, Directive 94/62/EC asked Member States to ensure that systems are set up for the return and/or collection of used packaging and for its reuse or recovery. Its recitals held it essential that those involved in the production, use, import and distribution of packaging accept responsibility for packaging waste under the polluter-pays principle.
2. 2008. Article 8 of Directive 2008/98/EC, titled Extended producer responsibility, allowed Member States to take measures to ensure that the producer of the product has extended producer responsibility.
3. 2018. Directive (EU) 2018/851 inserted Article 8a, General minimum requirements for extended producer responsibility schemes, into Directive 2008/98/EC. An extended producer responsibility scheme is a set of measures taken by Member States to ensure that producers of products bear financial responsibility or financial and organisational responsibility for the management of the waste stage of a product's life cycle, under Article 3, point 21, of that Directive.
4. 2018. Directive (EU) 2018/852 replaced Article 7 of Directive 94/62/EC and required extended producer responsibility schemes for all packaging by 31 December 2024.

What Does the PPWR Change in That History?

Regulation (EU) 2025/40 puts the packaging producer's extended producer responsibility into a directly applicable regulation that builds on Directive 2008/98/EC. Under Article 71, Regulation (EU) 2025/40 has applied since 12 August 2026. Under Article 70(1), Directive 94/62/EC is repealed with effect from 12 August 2026, with exceptions. Articles 44 to 46 cover registration, EPR and producer responsibility organisations.

Under Article 45(1), producers have extended producer responsibility under the schemes established in accordance with Articles 8 and 8a of Directive 2008/98/EC and with the Regulation's EPR section, for the packaging they first make available in a Member State. Recital 122 states that the Regulation builds on the extended producer responsibility requirements laid down in Directive 2008/98/EC. Recital 127 gives the reason for harmonising: there are wide disparities in the way extended producer responsibility schemes are set up, in their efficiency and in the scope of responsibility of producers.

Under Article 44(2), producers register in each Member State where they make packaging or packaged products available for the first time. Under Article 46(1), producers may entrust their extended producer responsibility obligations to a producer responsibility organisation authorised in accordance with Article 47. A producer responsibility organisation is a legal entity that financially or financially and operationally organises the fulfilment of extended producer responsibility obligations on behalf of several producers, under Article 3(1)(66). Under Article 45(3), a producer referred to in Article 3(1)(15)(c) and (d) appoints an authorised representative for the extended producer responsibility in each Member State, other than its own, where it first makes packaging available, a rule discussed in our article on two petitions and the Commission's reply.

Why Does the History Matter to a Company Selling in Several Markets?

The history of packaging EPR matters to a company selling in several markets because the same principle applies under separate laws. Regulation (EU) 2025/40 is directly applicable in the Member States under Article 71, so a company that also sells in Japan, Korea, Chile, California or Ontario meets each of those regimes under its own law and authorities.

1. One registration per regime. Registration under Article 44(2) is made Member State by Member State. The Official Journal text of Regulation (EU) 2025/40 does not name Japan, Korea, Chile, California or Ontario.
2. One producer per regime. Under Article 3(1)(15), the EU producer is the manufacturer, importer or distributor that first makes the packaging or packaged product available on a Member State's territory. The Korea Environment Corporation names producers and importers. See our guide to importer obligations for non-EU manufacturers.
3. One record, several reports. Maine producers report the amount of packaging material associated with products sold in or into Maine, according to the Maine DEP. One record of materials and weights per packaging reference can serve that report and the EU duties in our PPWR checklist, role by role.

What Does the Referential Not Confirm?

Our dated PPWR referential (baseline reviewed 15 September 2026) covers Regulation (EU) 2025/40 only and confirms one statement in this article, the scope of Article 2(1). Every other point below was read on the linked text on 27 September 2026.

• Articles 3(1)(15), 3(1)(66), 44(2), 45(1), 45(3), 46(1), 70(1) and 71, recitals 122 and 127, and the absence of the five non-EU names cited above, read on the Official Journal text, not recorded in our referential.
• Every statement on laws outside the Union, the OECD, the dissertation and the four directives, which may change after that date; nothing here is legal advice.
• Not established: the first packaging EPR law in the world, and the creation date of the Green Dot. The outline of Japan's Ministry of the Environment says the Act was enacted in 1997; this article uses the Act's own number and date, read in a translation without legal effect.

Frequently Asked Questions

Who invented extended producer responsibility?

Thomas Lindhqvist introduced extended producer responsibility as a defined policy strategy in a 1990 report to the Swedish Ministry of the Environment, according to his 2000 dissertation at Lund University. The OECD dates the emergence of extended producer responsibility in a number of OECD countries to the late 1980s.

Was the German Green Dot the first packaging EPR system?

The sources read here do not say so. A 1998 Bundestag document describes the ordinance of 12 June 1991 as the first comprehensive regulation of product responsibility in waste management in Germany, and credits the dual system Der Grüne Punkt with about 25 million tonnes of sales packaging recycled from 1993 to 1997.

How PPWR Connect Helps

PPWR Connect is software, not a producer responsibility organisation, an authorised representative or a legal adviser. A SKU can be recorded as sold in California (US-CA) or Ontario (CA-ON), not only in an EU country, and a per-market obligation profile answers who the producer is in each jurisdiction. EPR declarations record what they were computed from and can be generated per UK semester. To map your markets jurisdiction by jurisdiction, start with our PPWR compliance software or the PPWR readiness assessment.

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Rutherford (rutherford.fr) develops production control software for offset printers and converters, including ColorLoop. Veoria (veoria.com) develops inline colour measurement for label and packaging presses, including DeltaOne.