EPR, put simply
Extended Producer Responsibility, EPR, is a simple idea. If you make or sell a product, you pay in advance for what happens to it when it is thrown away. For a brand or retailer, it works like this: for every item you place on the market, you pay a small fee into a collective body, usually called a Producer Responsibility Organisation. That body uses the money to fund collection points, sorting, recycling, and the campaigns that ask consumers to bring things back. In France, the fee on a T-shirt is about three cents. The principle is that the cost of the end of a product’s life is built into its beginning, so that dealing with waste is paid for by the people who create it rather than by the taxpayer.
If the concept is simple, why are we going in circles?
If the idea is that simple, why does it produce wildly different results? In the United States, lead-acid car batteries come back at close to 99 per cent, the highest rate of any consumer product, and the European industry reports similar. No deposit scheme drives it, no awareness campaign, and there is barely an EPR fee. Clothing, with nearly twenty years of EPR behind it in France, is still mostly thrown in the household bin, and the scheme that exists runs on support payments that have to keep rising. Same idea. Opposite outcomes.
The shared problem at the centre of the circle
The difference is not the scheme. It is what the object is worth now that its useful life has come to an end.
A battery vs a T-shirt
A dead car battery is worth money. Lead can be recycled almost endlessly and commands a real market price, so recyclers pay for spent batteries rather than charging to take them. When the object pays for its own return, nobody needs persuading, and no fee is needed. The loop closes on its own.
A worn garment is the opposite case. It costs more to collect and sort than the recovered material earns back. The European baseline figures make it concrete: for the fraction that cannot be worn again, sorting adds roughly eleven cents of value per kilogramme and costs roughly sixty-eight cents per kilogramme (Fashion for Good and Circle Economy, Sorting for Circularity Europe, 2022). The gap is covered by the EPR fee, and in France by a support payment to sorters that the state has just ordered raised to 268 euros per tonne, paid out of the same producer fees. The fee exists precisely because the object cannot pay.
Logistics play a part too: swapping a car battery at a garage is not the same errand as clearing out a wardrobe. But the logistics follow the value. If a worn T-shirt were worth real money at the end of its life, the means of collecting it would be designed to match. And that is where this story is going.
That gives you the rule that explains the whole landscape: the size of the EPR fee is roughly the inverse of the object’s value. Where the material is valuable, the fee is small or absent. Where the material is worthless, the fee is large, and it does all the work.
And still - the money is not enough
The fees are not enough, and the money is not reaching the actors who need it. Textile sorters across Europe have closed or entered administration as the value of collected clothing collapsed. Less than one per cent of textiles become new textiles (Ellen MacArthur Foundation). The latest industry assessment, from BCG and ReHubs in March 2026, puts the cost of scaling textile recycling at 8 to 11 billion euros in investment, plus 5 to 6.5 billion euros per year to operate. The simple answer is to raise the fees. But a fee on a three-cent T-shirt can only be pushed so far, and every increase restarts the same argument about who pays. The funding debate never resolves, because the thing being funded keeps losing value.
A shift in mindset to capture more value
Every number above stems from one inherited assumption: that the only value in the system is the residual value of the object, based on what we can do with it if we choose not to burn or landfill it.
That mindset has its origins in waste management. It is more than thirty-five years old, and it survives in every scheme design tried anywhere, whether run by a single national body, competing commercial operators, or a government administrator.
As a mindset it poses an existential risk to the system, and we wonder why it is failing. If the object’s value is the only value you measure, and the object’s value is falling, then the only move the system has is to ask for more money, and the status quo prevails by construction.
But there is a second value, created at exactly the same moment: the person standing in the store. Someone who was motivated enough to keep an item and carry it back has just demonstrated, in person, the exact behaviour every brand spends marketing budget trying to find. That interaction has a market price. The system records the weight of what they were carrying and nothing else.
The numbers: object vs person
If the moment of return can be captured, identified, consented, verified, the system unlocks a value large enough to change its economics to net positive. The moment is already being created, every day, by existing scheme design. It is lost because the person drops the item into a collection box, the box records a weight, and nothing records the person.
Value A, the object. A returned garment is worth, at best, a few tens of cents after sorting. For the average item the honest figure is negative: it costs more to process than it returns.
Value B, the person. Ask a different question: what is a captured, consented customer moment worth to a retailer or a brand?
The market answers that question every day. Retailers pay 12 to 25 euros to acquire a customer through paid social, and 18 to 31 euros through website sign-up prompts. A consented contact alone is commonly valued at 1 to 5 euros; that one is an industry rule of thumb rather than a study, but it is the rule of thumb marketing departments budget by.
Scheme designers have already concluded that the store is the answer for access:
- European WEEE rules oblige retailers to take back an old appliance when they sell a new one, and larger stores to accept small electronics with no purchase required at all.
- The EU Batteries Regulation requires any shop selling batteries to take spent ones back free of charge.
- France’s textile scheme builds its network around territorial coverage, a collection point within practical reach of every household, and in-store drop points count toward it.
The reasoning in every case is access: the store is where people already are. But in every one of these designs, the retailer’s role is framed as asking a favour and perceived as a cost: floor space given up to a collection box, and nothing to show for it. Nothing anywhere prices the value the moment creates for the retailer, even though their own marketing department prices the same customer in every other channel it runs.
The schemes have concluded that retail is key for access, and then left retail to support it in good faith. The most valuable link in the chain is not measured or factored in, and we wonder why it is weak.
What changes if we count both
Here, the behaviour can come from the field rather than from benchmarks alone. In the published pilot with our Dutch retail partners, more than six hundred identified customers brought back more than seven hundred and fifty pairs of shoes, on trips they were already making, and identification at the point of return ran at around 90 per cent.
Scale that to a thousand identified customers, and you get roughly twelve hundred and fifty pairs, close to a tonne of footwear kept out of landfill or incineration.
The object side. Our own processing costs are commercial, so use the published European benchmark instead: sorting a tonne of non-rewearable textiles costs about 680 euros and returns about 110 euros of value. Call the gap roughly 570 euros. That gap is why EPR fees exist.
The person side. A thousand consented, identified customer moments. Value each at one euro, the very bottom of the rule-of-thumb band for a consented contact, and the person side is worth 1,000 euros: already more than the gap on the object side. Value each at twelve euros, the bottom of what the market pays to acquire the same customer through paid social, and it is 12,000 euros: more than twenty times the gap.
To be clear about what this is: no published source prices this moment at all, so we are using what the market pays for the same person in other channels as the nearest proxy. It is an estimate, and we label it as one. The point survives at every level of caution: even the most conservative reading covers the cost the whole funding debate is about.
Retailers are being asked to host collection, but not to have anything to show for it. Change that single factor and they become the most powerful collection network we know, and its best advocates. It requires the EPR schemes and PROs to align, capture and report, and it requires being clear about who gains what. The retailer and the brand capture the engagement value, which turns hosting a collection box from an unpaid favour into a return. What the scheme gains is not cash but a motivated network, and the behaviour change it is already spending money to create.
This is deliberately simplistic, and product categories will differ. But count the customer alongside the object, and the economics of EPR are fundamentally changed.
Full evidence base, with sources, on our research pages.
