Extended Producer Responsibility (EPR) is a policy approach where producers are held responsible for the entire lifecycle of their products, especially their end-of-life management. This shifts the burden from local governments to manufacturers. It encourages them to design more sustainable products, reduce waste, and invest in collection, recycling and reuse systems for packaging and other materials. 

The Personal Care Products Council recently produced a webinar that looked at the issues surrounding EPR and its impact on the personal care industry. Happi sat down with PCPC President and CEO Tom Myers to get his take on this far-reaching program.

Happi: What’s the overall message that PCPC has about EPR?  
Tom Myers: Extended Producer Responsibility is no longer a concept that people are discussing. It’s here and it’s complex. As EPR continues to expand, we support well-designed EPR laws that balance shared financial responsibility between producers and governments, harmonize requirements across states, and recognize the unique health, safety, and multi-use nature of cosmetic and personal care packaging.  

Overcoming Pain Points

Happi: What are the biggest pain points for PCPC members?  
Myers: Both the beauty industry as a whole and our member companies face several challenges, including the patchwork of inconsistent state laws and programs, lack of time to establish the appropriate tools for tracking and data collection and reporting, and high compliance costs—especially for small and medium-sized companies.   

Material categorization of packaging also remains an issue for several reasons. There’s an overall lack of recognition that over-the-counter products and cosmetic packaging is subject to FDA safety requirements. Packaging plays a vital role in ensuring the safety of cosmetic products and is the critical first step in protecting product formulas from contamination and degradation. In addition, packaging material and structure are uniquely designed and produced to maintain product integrity. Some products are considered small format, have multi-material packaging and the packaging serves as the application system for the product. If you take mascara, for example, the packaging is in small format, with multiple packaging components and the package itself serves as its delivery system.  

Greater investment in recycling flexible films is also needed. The material serves a critical function to ensure the safety of cosmetics and is difficult to recycle using mechanical recycling methods. New technologies, such as molecular recycling or dissolution, will play a critical role in increasing the recycling rates for flexible films.   

Happi: How is PCPC helping alleviate those pain points?  
Myers: We are addressing the challenges through a multi-prong approach that includes education and advocacy. For example, we offer online educational sessions and provide access to a multidisciplinary team of experts. We are also engaging with regulators to secure exemptions where necessary, advocating for harmonization across states, providing technical input on recyclability lists and material criteria, and working with packaging producer responsibility organizations to streamline compliance and reduce administrative burdens for our industry.  

Happi: Has PCPC estimated what the cost of EPR will be for its members? Can you share that info?  
Myers: We have not established specific cost estimates for EPR as they vary from state to state. However, we have cautioned that poorly designed EPR frameworks could lead to disproportionate costs and fines, and impact product accessibility.   

Benefits & Recommendations

Happi: Has PCPC identified benefits of EPR for its members? If so, can you elaborate?  
Myers: We see several opportunities regarding EPR. Well-designed EPR can drive innovation in packaging, expand recycling infrastructure, increase packaging circularity, support consumer education, and improve trust in industry by aligning environmental objectives with health and safety priorities.  

Happi: What would PCPC like to see happen regarding EPR?  
Myers: We recognize that EPR is complex and expanding; however, we strongly recommend:  

• National standards and definitions for recyclable, reusable and compostable to avoid a costly state-by-state patchwork;  
• A greater harmonization of definitions for “producer” and other terms, covered material categories, timelines and reporting requirements across jurisdictions;  
• Clear exemptions for OTC products and tamper-proof packaging where safety requires it;  
• Support for and recognition of the critical role advanced recycling technologies will play in increasing the circularity of hard-to-recycle materials like flexible films;  
• Acceptance of new recycling capabilities, such as those that allow for small format packaging to be recyclable or take back programs; and  
• An increase in consumer education initiatives to empower individuals to recycle more effectively and sustainably.