Monika Romenska
EXPRA
The Environmental Forum 2026 in Bucharest (3–5 March) brought together European and national institutions, sector organisations, and private partners to discuss legislative challenges, operational impacts of EU regulations, and circular economy initiatives. One of the key sessions, “Legislative challenges and implementation of European regulations,” set the stage for an engaging exchange of perspectives, where Monika Romenska (Regulatory & Public Affairs Manager at EXPRA, ISWA Member) shared insights on the evolving European landscape for EPR, and Prof. Aleksandra Anić Vučinić (ISWA Board Member) presented Croatia’s producer responsibility schemes.
From Concessions to Central Coordination
Croatia’s system has undergone significant changes over the past two decades. Between 2006 and 2021, producer responsibility relied largely on long-term concessions (10–20 years) for recyclers and collectors, with producer fees defined by regulation and largely fixed for many years. This approach created persistent challenges: difficulty in identifying responsible producers, limited oversight by producers themselves, and fragmented operational control.
During 2021–2025, Croatia introduced public calls for operators and recyclers and established a Council for Spatial EPR to coordinate activities and improve transparency. This period marked a transitional effort to strengthen governance and prepare for a more comprehensive cost-recovery framework.
The Full-Cost System and Remaining Challenges
Since 2025, Croatia has moved toward a full-cost system, designed to reflect the actual costs of collection, treatment, and administration. Prof. Aleksandra Anić Vučinić, together with her university team, conducted a detailed study to develop methodologies for calculating these costs, providing guidance for policymakers navigating political and practical constraints.
However, the forum discussions highlighted a key criticism: state-run PROs are often not considered genuine EPR by many stakeholders. Unlike industry-led PROs, which can adapt more flexibly to market conditions, respond to changing product streams, and adjust fees dynamically, state-managed models may be slower to innovate and less responsive to operational realities. This debate underscores the differences between centralized/State run and the benefits of producer-led governance in achieving both compliance and efficiency, not to mention that State run PROs are excluded from the EPR requirements set in Art 8a of the Waste Framework Directive.
However, the forum discussions highlighted a key criticism: state-run PROs are often not considered genuine EPR by many stakeholders. Unlike industry-led PROs, which can adapt more flexibly to market conditions, respond to changing product streams, and adjust fees dynamically, state-managed models may be slower to innovate and less responsive to operational realities. This debate underscores the differences between centralized/State run and the benefits of producer-led governance in achieving both compliance and efficiency, not to mention that State run PROs are excluded from the EPR requirements set in Art 8a of the Waste Framework Directive.
Other ongoing challenges for State-run PROs include politically influenced fee calculations, difficulties in identifying all obligated producers, and integration with the RSWC digital reporting system, which tracks waste streams and compliance.
Operational Insights and Circular Economy
Sessions emphasized translating policy into measurable results. Croatia’s experience illustrates how fragmented systems can evolve into more structured frameworks, improving transparency and operational control. It also highlights the trade-offs between political oversight and market-driven flexibility, a critical lesson for countries seeking to implement effective producer responsibility schemes.
