Plastic packaging waste statistics in function of EPR design

(2026)

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Abstract
Accurate plastic packaging waste generation statistics are foundational to the governance of the circular economy in the European Union (EU). Yet the dominant estimation method, which derives plastic packaging waste generation statistics from producer declarations collected through Extended Producer Responsibility (EPR) schemes, is structurally vulnerable to underreporting. This study examines the extent to which the organisational design of EPR schemes influences plastic packaging waste statistics across EU Member States. For this purpose, three governance dimensions are analysed: market structure (single vs. competing Producer Responsibility Organisations, or PROs), profit orientation of PROs, and the degree to which Member States rely on EPR-generated put-on-market (POM) data for official Eurostat reporting. The analysis draws on Eurostat plastic packaging waste data covering 2005 to 2023, EPR governance classifications from EUROPEN (2025), and national reporting methodology information from Member State quality reports. Descriptive group comparisons are the primary analytical method covering 25 Member States, supplemented by Welch's independent samples t-tests for the market structure dimension. Three main findings emerge. First, the average reported plastic packaging waste (PPW) generation and recycling volumes per capita between 2005 and 2023 is significantly higher for Member States with single (monopolistic) PRO systems compared to Member States with competing PROs. The difference in recycling rates does not reach statistical significance. Second, PRO systems operating with a for-profit orientation report lower average PPW generation per capita between 2005 and 2023 than non-profit systems. However, large within group variability limits interpretability. Third, Member States relying exclusively on EPR-generated POM data report lower average PPW generation and higher apparent recycling rates compared to those partially or not reliant on POM data. In terms of PPW recycled per capita, the differences are minor. The pattern is consistent with systematic underreporting embedded in EPR-based data collection. The study concludes with two policy recommendations: mandatory cross-checking of POM data against independent sources, and strengthened independent auditing of PRO declarations. Both are grounded in existing provisions of the Packaging and Packaging Waste Regulation that await consistent national implementation.