Extended Producer Responsibility in the Context of Pharmaceutical Waste in the European Union

Abstract

Pharmaceutical waste is a challenge for the environment and public health in the European Union (EU). Although EU legislation requires Member States to establish collection systems for unwanted household pharmaceutical products, there is no common legal framework governing the application of extended producer responsibility (EPR) in this area, which has led to differences in the financing, organization, and effectiveness of national waste collection systems. Against this background, the aim of this work was to critically examine the role of EPR in the management of household pharmaceutical waste in the EU by analyzing its legal foundations, comparing selected national take-back systems, identifying the barriers to its implementation and indicating the key elements of a future EU regulatory framework. The analysis indicates that key elements of the future EPR framework for pharmaceutical products should include financing for producers through producer responsibility organizations (PROs), free and accessible collection of medicinal products from patients through community pharmacies, full cost compensation for collection point operators, common reporting requirements, environmentally differentiated producer contributions, consumer education, and independent public oversight. The future EU framework could build on good practices developed in Member States with established EPR systems and on the regulatory solutions adopted in EU environmental legislation.