EPR

EPR Reporting and Declaration: The Challenges, Hidden Costs and Consequences

EPR Reporting and Declaration: The Challenges, Hidden Costs and Consequences

Oct 23, 2025

Shahan Syed

Product Marketing Manager

Key Takeaways

  • Understand the dual nature of Extended Producer Responsibility (EPR) reporting challenges: external regulatory complexity and internal process inefficiencies.

  • Discover the hidden costs—both opportunity costs (like wasted time and productivity) and direct costs (such as fines and overpaying)—that result from traditional methods.

  • Explore how adopting a digital strategy can streamline your compliance journey, save time, and reduce annual EPR expenditures

In the broader landscape of corporate responsibilities, Extended Producer Responsibility (EPR) reporting and declaration often take a back seat. Many organisations approach these declarations reactively, rather than adopting a strategic and proactive mindset.

While this might be working for now, this approach might cost you in the long run, especially in today's evolving EPR landscape.

How so? In this article, we break down the complexities involved in the process and the hidden costs of ignoring them.

Challenges Faced in EPR Reporting

EPR reporting comes with a unique set of challenges that can generally be divided into two categories:

  • Those arising from the constantly evolving EPR landscape; and

  • Those stemming from traditional, inefficient internal processes.

EPR Environment Challenges

New countries being introduced

The EPR map is being redrawn. Key markets like the United Kingdom and Denmark are launching their comprehensive EPR schemes, while specific regions of the U.S (e.g., Colorado) are introducing their own frameworks, adding new, distinct sets of rules to the compliance puzzle.

Existing schemes are getting more complex

Established EPR frontrunners are not standing still. Countries like France and the Netherlands now refine their methodologies annually, introducing highly granular eco-modulation criteria that tie fees to factors such as recyclability, recycled content, material types, and even specific details like colour.

What was once a task of declaring tonnes placed on the market has evolved into a complex data challenge.

Evolving regulations

EPR schemes are anything but static. Fee rates, material classifications, and calculation methodologies are being revised year after year-forcing companies to re-evaluate and adapt their reporting approach continuously.

For example, CONAI in Italy has already changed their EPR fees multiple times this year, with the latest update applying in 2025.

Process Challenges

Fragmented and incomplete packaging data

Packaging data that is needed for EPR is usually scattered and incomplete, which further complicates the declaration process. Many organisations also struggle to determine which data points are required, as these differ by country.

The result? Teams find themselves chasing stakeholders and suppliers to fill data gaps-often at the last minute, just before a reporting deadline.

Manual methods are inefficient

When it comes to EPR calculations, most of these are being done by spreadsheets or manual logic-based systems. This approach requires manually mapping complex EPR rules into formulas, leaving room for human error and consuming significant time and resources.

The problem intensifies when regulations and fees change, requiring you to make tedious calculation adjustments, or, even worse, discard previous work and start the entire process over.

Hidden Costs and Consequences of using Traditional Methods for EPR Reporting

Failing to adopt a proactive, streamlined approach results in two major types of consequences:

Time - Opportunity Cost

The biggest drawback of an unstreamlined process is the amount of time it consumes-time that could be better spent on more productive activities.

Resources also need to spend a considerable amount of time understanding regulatory changes in the evolving EPR landscape.

As a result, packaging, sustainability, and finance professionals spend more time on inefficient EPR tasks, pulling them away from other productive activities tied to their core responsibilities and even career growth.

Direct Costs

Legal action and fines

Not reporting EPR on time or reporting inaccurately can result in fines and legal action, which incur additional indirect costs for the company.

More importantly, instances like this can impact the reputation of stakeholders involved in the reporting and declaration process.

Overpaying and not optimising

With deadlines approaching, inefficient processes, and limited visibility into packaging and EPR data, companies often miss the opportunity to identify and act on potential cost savings.

The constantly evolving EPR landscape further complicates this, making it difficult to leverage eco-modulation benefits effectively.

As a result, EPR expenses tend to rise year after year.

A Digital Strategy for Better EPR Management

It's impossible to eliminate all these challenges, but you can build a more resilient strategy to better manage them, and this is possible by adopting a digital approach to EPR.

Our powerful digital platform at Recyda can help here. We enable companies to streamline their EPR reporting and declaration through a centralised platform-from packaging data management to reporting and portfolio optimisation.

Go on the digital EPR declaration journey with us, essentially helping you across these key areas:

  • Data unification and enrichment-consolidate packaging data and fill the gaps needed for accurate reporting.

  • Calculation and forecasting-automate fee calculations and anticipate future obligations with confidence.

  • Reporting and declaration-generate accurate, country-specific reports with minimal effort.

  • Portfolio visualisation and optimisation-identify cost drivers and opportunities to reduce risk and fees across markets.

Learn more about our EPR reporting and compliance platform.

Or, deep dive further into the topic by downloading our comprehensive guide on Building a Resilient Future-proof EPR Strategy. This guide not only further discusses the challenges mentioned above, but also lays down the strategic framework to better manage them in the future.

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