EPR for WEEE: Extended Producer Responsibility in 2026

Every year, hundreds of millions of electrical and electronic devices reach the end of their useful life. Disposing of them correctly is not simply an environmental aspiration — it is a legal responsibility assigned directly to manufacturers and importers through the principle of Extended Producer Responsibility (EPR) for WEEE (Waste Electrical and Electronic Equipment). In 2026, with the entry into force of new Italian regulations implementing Directive (EU) 2024/884, understanding EPR for WEEE has become a strategic imperative, not just a compliance checkbox.

Why EPR for WEEE Has Become a Business Priority

The global market for electrical and electronic equipment generates relentlessly growing waste volumes. According to data from the Italian WEEE Coordination Centre (CdC RAEE), Italy collected 366,891 tonnes of domestic WEEE in 2025 — an increase of 2.4% over the previous year, equivalent to 6.22 kg per inhabitant. These figures represent progress, but the collection rate still falls short of 40% of the average weight of EEE placed on the market over the preceding three years, against the 65% target set by Directive 2012/19/EU and transposed into Italian law by Article 14 of Legislative Decree 49/2014.

This gap is more than an environmental metric: it also reflects the level of compliance throughout the supply chain. Producers and importers of electrical and electronic equipment (EEE) who fail to meet EPR obligations expose themselves to regulatory sanctions, market exclusion, and growing reputational risk in a business environment where ESG criteria are increasingly shaping procurement decisions, investor relationships, and public tenders. Understanding the regulatory framework is the first step toward turning a legal obligation into a competitive advantage.

The Legal Framework: From Legislative Decree 49/2014 to D.Lgs. 2/2026

The Italian EPR framework for WEEE is built on Legislative Decree No. 49 of March 14, 2014, which transposed Directive 2012/19/EU into national law. The decree defines who qualifies as a producer under the regulation, sets out the categories of EEE subject to obligations, and governs registration with the National EEE Register (Registro AEE), administered through the Italian Chambers of Commerce.

The framework evolved significantly with Legislative Decree No. 2 of January 7, 2026, which entered into force on January 24, 2026, transposing Directive (EU) 2024/884. The decree acts on two distinct fronts: under Article 28, it updates the technical marking requirements for EEE, aligning them with standard CEI EN 50419:2023-02 and tying them to the market-placement dates already in force under existing rules (August 13, 2005, for identification of post-2005 products); separately, it defines the treatment of historical professional WEEE and the related allocation of financing costs for so-called "open scope" EEE, whose scope opened on August 15, 2018, as well as for photovoltaic panels marketed from August 13, 2012.

How EPR for WEEE Works: Individual vs. Collective Schemes

At the heart of the EPR for WEEE system lies the obligation on producers to finance the collection, treatment, recovery, and environmentally sound disposal of WEEE. The regulation offers two compliance paths:

• Individual system: the producer independently organizes and finances the end-of-life management of WEEE generated by its own products.
• Collective system: the producer joins a consortium or collective scheme that manages WEEE on a national basis, with costs allocated in proportion to each member's market share.

In Italy, collective systems dominate the market. The largest operator is Erion WEEE — formed from the merger of Ecodom and Remedia in 2020 — which managed over 244,000 tonnes of WEEE in 2025, representing approximately 65% of domestic WEEE in Italy. Cobat RAEE is another significant collective scheme, with particular strength in the professional segment. The CdC RAEE (WEEE Coordination Centre) coordinates all collective schemes and ensures uniform territorial coverage, guaranteeing WEEE collection from municipal drop-off points across the country.

New Marking Obligations Introduced in 2026

Legislative Decree 2/2026 brings one of the most significant regulatory updates in recent years for EEE traceability. Producers must now affix to every EEE unit an identification mark compliant with standard CEI EN 50419:2023-02, containing at least one of the following: the manufacturer's name, a registered logo, or the registration number in the EEE Register.

The dual goal is clear: to facilitate controls along the recovery chain and to link producers directly to the lifecycle of their products. The durability of the marking — verified according to section 4.2 of the technical standard — must be maintained for the product's entire useful life. This means companies need to review their manufacturing processes and labeling systems before bringing new product lines to market. For EEE already placed on the market, the deadline for complying with the new marking requirements must be checked case by case against the market-placement dates already set out in existing rules (August 13, 2005, for post-2005 identification), while August 15, 2018 remains relevant only for qualifying historical professional "open scope" WEEE and allocating the related financing costs.

2025 Collection Data: Where Italy Stands vs. European Targets

The CdC RAEE's 2025 annual report reveals a country moving in the right direction but still structurally distant from EU targets. With a national average of 6.22 kg per inhabitant collected, Italy falls well short of the objective set by the WEEE Directive. The geographic split is stark: Northern Italy achieves 7.02 kg per inhabitant, Central Italy 6.61 kg, while Southern Italy lags at 4.76 kg.

Erion WEEE — which manages the largest market share — recorded 3% growth in 2025, driven mainly by large household appliances (+5.4%) and small appliances (+5.1%), while the TV and monitor segment declined by 9.7%. These figures highlight how collection volumes remain closely tied to product replacement cycles rather than to the systematic, capillary collection model that the EPR framework ultimately aims to establish.

From Compliance Obligation to Competitive Advantage

For industrial decision-makers, EPR for WEEE compliance is no longer a matter that ends with formal registration. In a context where ESG criteria influence supply chain choices, investor dialogue, and public procurement, demonstrating responsible product lifecycle management has become a genuine differentiator.

Joining a well-structured collective scheme, updating marking processes in line with D.Lgs. 2/2026, and maintaining a current, compliant Registro AEE registration are non-negotiable steps. But the most forward-thinking companies are going further: integrating WEEE collection data into sustainability reports, quantifying the CO2 emissions avoided through material recovery, and translating managed volumes into ESG metrics that resonate with stakeholders. Viewed through this lens, EPR for WEEE ceases to be a cost center and becomes the foundation of a measurable, credible environmental responsibility strategy.