In Germany BTE (German Association for textile & shoes, leather ware ) and colleague trade associations have presented a statement on the EU commission’s draft for a proposed harmonized system of “extended producer responsibility” in all Member States. Some highlights:
- According to BTE and its fellow associations, the criteria and calculation of eco-modulated fees must be based on identical criteria in all member states. As it must be clearly defined which relevant criteria refer to ‘ecologically produced products’.
- In addition, the introduction of the EPR fees must take place together with the “Digital Product Pass” (DPP), as the DPP can be used to pass on the necessary information on the product.
- It is also desirable to take the life cycles of products into account when grading contributions.
- The EPR fee should be used, among other things, to support research and development on sorting and recycling technologies, as well as on consumer education.
Finally, the statement presses for equal and fair conditions of competition for all market participants who sell goods in the EU. In that respect, Asian platforms must be subject to the same regulations and appropriate controls must be carried out.

























