Statement – 19^th November 2025

PROs and individual systems

We need the same rules for everyone

In the proposal for a circular vehicle regulation is described that EPR (extended producer responsibility) needs to be organized by producers (OEMs or original equipment manufacturers)  (article 16) or mandated to PROs (producer responsibility organisations) (article 18).

Apart from the discussion about compensation and how to calculate, EGARA has some reservations about EPR systems.

If OEMs are organized in a PRO, it’s the ideal form for ATFs as they only deal with one operator. In case of individual systems (each OEM for it’s own) it means dealing with many operators, as many (if not most) ATFs receive all brands of vehicles. This would mean a lot of unnecessary administrative burden and makes EPR unnecessary complex.

If in a country is chosen for individual systems anyway, these systems should be all alike. They should meet up to certain standards and formats. Not only nationally, but also internationally. There should be no differences in these individual systems. These systems should be open for anyone that meets objective verifiable conditions, preferably audited by independent auditors. This way it’s prevented that OEMs are to decide what ATF can survive and which have no rights for further existence.

Individual systems should never lead to al kinds of extra restrictions and obligations, like restrictions in parts sales or mandatory delivery of parts or materials.

Also it should only be ATFs that can join an Individual system or PRO, not dealers, shredders, collection points or other operators that aren’t ATFs. On the other side, in case of PRO’s they can be directed not only by OEMs or importers, but also by other automotive operators in order to be independent and neutral in their policies.

PROs and individual systems take care of EPR matters, even if manufacturers no longer exist. ATFs need to be protected against costs that cannot be claimed because the responsible OEM can’t be approached.

EGARA is of opinion that in order to provide EPR, uniform reasonable systems are evident.