EXPRA Key Recommendations for the Circular Economy Act Extended Producer Responsibility (EPR) is a cornerstone of the EUs circular economy and waste policy. As the EU prepares the Circular Economy Act, it must protect EPRs integrity so it continues to deliver environmental and economic value. EPR must remain producer-led, fair, and adaptable to challenges such as e-commerce and changing consumer behaviour. 1.
EXP
EXPRA
Industry association · Belgium · EU Transparency Register 382147211686-77
9
positions filed
in the 665 files tracked
8
legislative files
of 665 tracked
9
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 665 consultation files tracked so far (57,774 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
Who they are
Among the 1518 trade and business associations on this site, they rank #427 by legislative files engaged, a count of participation, not a measure of influence.
2
declared lobbying FTE
self-declared
€300K+
declared costs / yr (floor)
3
EP accreditations
as declared to the register
2013
in the register since
Declares membership of
- Mitgliedschaft in ISWA (International Solid Waste Association) www.iswa.org,
- Clean Europe Network, https://www.cleaneuropenetwork.eu/
- CEFLEX, www.ceflex.org
- HolyGrail 2.0
- 4EverGreen →
- Close the Glass Loop
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026).
- Register category
- Trade and business associations
- Registered as
- Extended Producer Responsibility Alliance (EXPRA)
- Head office
- Brüssel, Belgium
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026); cost bands are floors, not audited totals. Reused under Commission Decision 2011/833/EU.
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Their record over time
EXPRA filed 9 positions between 6 Aug 2020 and 17 Mar 2026, across 8 of the 665 legislative files tracked here, attaching a full position paper 9 times.
2020 · 1 filed2021 · 1 filed2022 · 2 filed2023 · 2 filed2025 · 1 filed2026 · 2 filed
What they argued
EXPRA POSITION PAPER ON PPWR The Extended Producer Responsibility Alliance (EXPRA), representing 32 non-profit national EPR organizations across Europe and beyond, supports the Commissions proposal to review the current packaging and packaging waste directive (PPWD).
The Extended Producer Responsibility Alliance (EXPRA), representing industry-owned, non-profit packaging and packaging waste recovery and recycling organisations, welcomes the opportunity to provide feedback on packaging waste prevention and essential requirements as part of the EU consultation on the PPWD review.
A future-proof legislative framework empowering EPR schemes to improve waste management EXPRA’s response to the call for evidence on the Waste Framework Directive Revision EXPRA supports a forward looking and ambitious regulatory framework for waste management which enables national and local entities to implement sound and efficient waste management systems.
EXPRA calls for regulatory consistency across Circular Economy legislations Input to call for feedback on the Ecodesign for Sustainable Products Regulation (2022/0095(COD)) EXPRA backs the ambitions set by the European Commission’s Proposal for an Ecodesign for Sustainable Products Regulation (ESPR).
EXPRA is pleased to provide the following feedback on the draft. If a non-plastic (for example paper) label is a part of the bottle, the methodology requires that it is deducted from the weight of the plastic bottle.
EXPRA and EPRO members support the development of harmonised end of waste legislation across the Union. The two Associations have prepared a joint Position Paper on the draft Implementing Regulation to develop end of waste criteria (EoW) for plastic, with input from members of both Associations.
Packaging Recovery Organisations, including the 27 members represented by the Extended Producer Responsibility Alliance (EXPRA) as well as CITEO and Altstoff Recycling Austria AG (ARA), would like to comment on the proposed methodology for the determination of the weight of separately collected waste single-use bottles (Article 2 of the draft Implementing Act).
The attached paper sets out EXPRAs feedback on the draft delegated decision concerning average loss rates. EXPRA welcomes the development of this important piece of secondary legislation, which will contribute to a more harmonised approach to calculating recycling rates across the European Union.
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Turns up on the same files
Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers, not evidence of coordination, and we do not suggest any.
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Everything on this page comes from EXPRA’s own submissions to the European Commission. We have added nothing and interpreted nothing. If something is wrong or out of date, email info@policyspeak.com and we will correct it. If you are an individual named in a record, our privacy policy sets out your rights to correction, objection and removal.
Quotes are verbatim from submissions published by the European Commission, trimmed to their opening passage and never summarized by a model. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.