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
4
positions filed
in the 326 files tracked
4
legislative files
of 326 tracked
4
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 326 consultation files tracked so far (29,503 submissions, mostly 2025–26), so an organization's real filing history is larger, not smaller.
Who they are
Among the 1205 trade and business associations on this site, they rank #406 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 30 Aug 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 30 Aug 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 4 positions between 30 May 2023 and 17 Mar 2026, across 4 of the 326 legislative files tracked here, attaching a full position paper 4 times.
2023 · 1 filed2025 · 1 filed2026 · 2 filed
What they argued
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.
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.
Looking for an argument rather than an organization? Search every submission for a phrase and see everyone who used it.
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.
- FEAD - European Waste Management Association · 4 files in common
- Plastics Recyclers Europe · 4 files in common
- Cefic · 3 files in common
- German Association of Biotechnology Industries (DIB) within the German Chemical Industry Association - VCI · 3 files in common
- BASF SE · 3 files in common
Showing 5 of 107.
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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.