The year 2022 marked a significant turning point in the enforcement of Extended Producer Responsibility (EPR) provisions under the EU’s Single-Use Plastics Directive of 2019. For beverage manufacturers, the shift was more than just regulatory noise—it forced a deeper reckoning with supply chain transparency and accountability. Producers of plastic beverage containers, among others, now carry the financial burden for the collection, transport, and treatment of post-consumer waste tied to their products. It is, in theory, a simple cause-and-effect framework: put plastic on the market, and you’re responsible for its end-of-life. Yet, the practical realities of mapping and managing these obligations are proving more layered.
What’s immediately clear is that national-level EPR registers have become the backbone of compliance efforts. Beverage manufacturers—large and small—are increasingly reliant on these open registers to track which suppliers are properly enrolled and contributing to national waste management systems. The logic is inescapable. If bottle suppliers are outside these registers, or reporting inaccurately, the liability risks cascade right down to the brand owners. And while most manufacturers had, at some level, anticipated this shift, the complexity of supplier mapping has caught more than a few off guard.
The first hurdle, for many, is simply assembling reliable data on supplier participation. National EPR registers across the EU do provide open access in varying forms, though the formats and levels of detail differ. Some offer downloadable datasets; others, clunky web interfaces that require more manual effort to parse. Either way, manufacturers are having to build or refine internal data pipelines that can cross-reference their supplier lists against these national records. It is, frankly, tedious work, but unavoidable if firms are to demonstrate compliance under both EU and national law. And as one supply chain manager put it, not without a hint of frustration, “the devil’s in the details—especially when the details are spread across 27 countries’ systems.”
Parallel to this is the task of integrating deposit-refund scheme data with Reverse Vending Machine (RVM) networks. Here, the ambition is to create closed-loop systems where packaging materials—particularly PET bottles—are efficiently recovered and reprocessed. The directive’s intent is clear enough, but operationalising it means beverage producers must ensure their own data feeds—on production volumes, redemption rates, refund outlays—mesh cleanly with those of RVM operators. The technical challenges are, in some cases, underestimated. Data formats don’t always align. Reporting cycles vary. And while many national schemes have central clearinghouses, these are not uniformly mature. Producers are learning, sometimes the hard way, that early investment in data standardisation can pay dividends in reducing compliance headaches down the line.
There is also, if one’s being candid, a certain tension between regulatory compliance and commercial priorities. Firms want, understandably, to minimise cost exposures. But the more granular the reporting and the tighter the integration with RVM networks, the harder it becomes to gloss over inefficiencies in collection or redemption. Some beverage manufacturers are now revisiting supplier contracts, inserting clauses that require clearer documentation of EPR contributions and deposit-refund compliance. Others are starting to explore shared digital platforms, perhaps blockchain-based, that could bring real-time visibility into bottle flows—from production to redemption. These are early days for such tools, and not all will gain traction. Still, the direction of travel seems unmistakable.
What complicates matters further is the divergence in national implementations of the directive. While the framework is EU-wide, individual member states have latitude in how they structure EPR obligations, deposit-refund schemes, and reporting requirements. This variability forces multinational producers to adopt a patchwork of compliance strategies—what works in Germany may be inadequate in Spain, or vice versa. It creates a certain fatigue, to be honest, among compliance teams. But there’s also, paradoxically, an opportunity: firms that can master this complexity may find competitive advantage in being able to demonstrate robust, verifiable sustainability practices to increasingly discerning consumers.
Some manufacturers are, cautiously, experimenting with integration of RVM data not only for compliance but as part of their broader ESG reporting. Redemption rates, bottle recovery volumes, and even geographic patterns of return are being folded into annual sustainability disclosures. The appetite for this among investors and regulators appears to be growing, though how much weight such data will carry in valuations or ratings is still open to debate. Nevertheless, the momentum is building.
The landscape is dynamic. The enforcement actions in 2022 sent a clear signal that EPR is no longer a paper exercise; the cost of non-compliance is tangible. But it’s also becoming evident that those who move beyond minimum compliance—who build resilient, transparent bottle supply and recovery chains—may be better placed to navigate future regulatory waves. The work, however, is detailed, ongoing, and in places frustratingly fragmented.