Opinion: 10 inconvenient truths about EPR in the global south

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Despite the critical role that Extended Producer Responsibility (EPR) plays in promoting a circular economy, Jose Ramon Carbajosa says the concept is “too often misunderstood, misapplied, or misused” in the global south. The result, he argues, is a persistent disconnect between EPR’s promise on paper and the realities of implementation on the ground.

• Mr Carbajosa is a circularity consultant who has worked in Africa, Latin America, and Asia, supporting the design and implementation of EPR systems.

• He says governments and stakeholders must design EPR systems grounded in local capacity, economic realities and institutional discipline. Without this foundation, he warns, “we risk wasting another decade of potential.”

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Extended Producer Responsibility (EPR) is widely regarded as a cornerstone of the circular economy. It’s a simple but powerful idea: the producers of products should be financially and operationally responsible for managing them once they become waste. When done right, EPR incentivises better product design, improves waste management, and attracts private investment into much-needed recycling infrastructure.

Yet across the Global South — where I’ve worked for years helping design and implement EPR systems — I’ve seen that EPR is too often misunderstood, misapplied, or misused. Despite good intentions and strong theoretical frameworks, the reality on the ground is frustrating, political, and in some cases counterproductive.

Here are ten truths I’ve encountered that we must talk about if EPR is to deliver real impact in Africa, Asia, and Latin America.

1. There’s deep mistrust between governments and the private sector.
  Instead of empowering producers to manage their responsibilities through Producer Responsibility Organisations (PROs), many governments opt for tight control. Public authorities often see private involvement as a threat, not a necessity — and design overly rigid, top-down schemes. This distrust cripples systems that depend on flexibility, scale, and entrepreneurial energy.

2. EPR is treated as a tax — not a responsibility mechanism.
  In several countries, EPR fees paid by producers are simply redirected into public budgets. This strips the system of its circular purpose and turns it into an environmental tax in disguise — with little or no traceability to outcomes.

3. Donor programs sometimes create EPR illusions.
I’ve seen well-funded, multi-year donor programs that sustain consultants, run endless stakeholder workshops, and produce glossy reports — but fail to implement a functioning system. The political economy often rewards appearance over substance, and governments tolerate these projects because they generate activity without real reform.

4. Many believe EPR fees should fund all waste infrastructure.
  A common misconception is that EPR will pay for everything: trucks, bins, sorting plants, treatment facilities. In truth, EPR is designed to leverage private investment, not replace it. It creates the certainty and regulatory structure that investors need — but it cannot and should not fund entire waste systems alone.

5. “One PRO per waste flow” is inefficient and risky.
  Some officials insist that their market is too small for multiple PROs, fearing complexity. But monopolies lead to complacency, low transparency, and political capture. Even small countries can support multiple PROs — as long as the rules of the game are clearly defined and monitored.

6. Unqualified companies are stepping in for the wrong reasons.
  In three West African countries, I’ve seen large multinationals — better known for customs control or inspection — offer to manage EPR systems, despite having no relevant experience. Their motive? Regaining relevance after losing contracts. In some cases, governments said yes. EPR becomes a fallback business model, not an environmental solution.

7. It’s called “EPR” to unlock funding — but it’s really a tax.
  In one Southern East African country, the government presented a new tax as “EPR” to satisfy donor criteria. The system had no producer governance, no eco-modulation, and no link to collection or recycling outcomes. Even more concerning, the donor’s own consultants went along with it.

8. Innovation without legal grounding is dangerous.
  In one case, consultants proposed an “innovative” financing method: instead of eco-fees, producers would deposit money into a national consignments fund. The aim was to give a government agency direct access to funds without going through the Ministry of Finance. The idea was pursued, declared unconstitutional, and the draft legislation was shelved. The entire process was donor-funded.

9. Without enforcement, good laws mean nothing.
  One West African country passed solid EPR legislation and approved a producer-led PRO — but never enforced it. Producers didn’t register or contribute. The system sat idle for eight years before relaunching with weaker targets.

10. Overambition with no resources is a recipe for failure.
  In one East African country, a comprehensive EPR law covered multiple sectors — electronics, packaging, textiles, and more. Thousands of producers were told to submit data via Excel files and join a PRO. The number of civil servants reviewing the submissions? Two.

The Way Forward: From Illusion to Impact

EPR isn’t failing in the Global South because the concept is flawed. It’s failing because we aren’t designing systems grounded in local capacity, economic reality, and institutional discipline. Governments, donors, and implementers must move beyond theory and optics — and get serious about design, governance, and enforcement.

EPR must be producer-led, government-regulated, and outcome-focused. We must stop confusing activity with progress — and start aligning incentives, institutions, and infrastructure around systems that actually work.

If we don’t face these hard truths, we risk wasting another decade of potential.