Introduction

The global circularity rate has fallen from 9.1 percent to 6.9 percent over five years, even as investment in circular economy initiatives has grown. The reason is not a lack of recycling capacity or funding. It is a missing layer of data at the exact point where products leave consumer hands, which is also the point where extended producer responsibility (EPR) laws in more than 70 jurisdictions require companies to report. This article explains why that gap exists, introduces a four stage EPR Data Readiness Scale for locating where a company’s compliance data actually stands, and outlines how to close the gap.

Key Takeaways

• The global circularity rate declined from 9.1 percent to 6.9 percent in five years, according to the Circularity Gap Report from Circle Economy Foundation and Deloitte, despite rising investment in circular economy initiatives.
• EPR legislation now spans more than 70 jurisdictions worldwide, and most of these frameworks require disposal and waste composition data that companies frequently do not have at the item level.
• The EU Packaging and Packaging Waste Regulation, binding from August 12, 2026, names this data requirement explicitly, including annual waste reporting obligations tied to EPR.
• The EPR Data Readiness Scale, introduced in this article, defines four stages of compliance data maturity: Estimated, Partial, Verified, and Audit-Ready.
• Verified disposal data built for EPR compliance also satisfies ESRS E5 resource outflow and waste disclosures under CSRD, reducing duplicate data collection.

Why Has the Global Circularity Rate Fallen Despite Rising Investment?

Supply chains offer near complete visibility from raw material to point of sale, but that visibility disappears the moment a product reaches the consumer. According to the World Economic Forum, this blind spot at the point of disposal is why circularity efforts lose ground even as investment rises.

The scale of the gap:

• Global waste generation is projected by the World Bank to rise from 2.56 billion tonnes in 2022 to 3.86 billion tonnes by 2050, a 50 percent increase
• Waste management already costs more than 250 billion dollars a year
• Only a fraction of a percent of waste-related data exists at the item level

This is not only an environmental statistic. It is the same data gap sitting underneath a rapidly expanding set of legal reporting obligations.

Extended Producer Responsibility Requirements by Jurisdiction

EPR is where the data gap becomes a legal exposure rather than an abstract measurement problem. It now spans more than 70 jurisdictions worldwide, requiring producers to take responsibility for collecting, recycling, and disposing of what they place on the market. Two jurisdictions illustrate how differently this obligation is structured in practice.

United States: seven states now have enacted packaging EPR laws, each through its own state statute rather than a single federal framework.

• Maine, LD 1541, enacted 2021
• Oregon, SB 582, enacted 2021
• Colorado, HB 22-1355, enacted 2022
• California, SB 54, enacted 2022, with civil penalties of up to 50,000 dollars per day per violation for noncompliance
• Minnesota, HF 3911, enacted 2024
• Maryland, SB 901, enacted 2025
• Washington, SB 5284, enacted 2025

The Circular Action Alliance acts as the designated producer responsibility organization in most of these states, giving multistate producers a single reporting interface even though each state’s covered materials, deadlines, and fee structures differ.

European Union: EPR is layered rather than state-by-state. The Waste Framework Directive, Directive 2008/98/EC, sets the general minimum requirements for any EPR scheme in Articles 8 and 8a. Specific product categories are then governed by their own instruments:

• Packaging: Regulation (EU) 2025/40, the Packaging and Packaging Waste Regulation, binding from August 12, 2026
• Batteries: Regulation (EU) 2023/1542, with Article 56 placing EPR on battery producers
• Electrical and electronic equipment: Directive 2012/19/EU (WEEE)
• Single-use plastics: Directive (EU) 2019/904, Article 8

Coverage varies by region and product category beyond these two jurisdictions, with packaging, electronics, and textiles among the most common categories in scope elsewhere. Regulators in both the United States and the European Union expect visibility into what happens after a product leaves the point of sale, and they expect that visibility reported by the producer, not reconstructed afterward through estimation.

What Data Do EPR Regulations Actually Require Companies to Report?

The EU Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, applies directly across all member states from August 12, 2026. It makes EPR reporting specific rather than aspirational.

Key requirements under the regulation:

• Packaging waste management operators must annually report packaging waste data to authorities and producers to support EPR obligations
• Distributors must verify that packaging complies with EU rules and provide relevant information to authorities upon request
• Packaging must meet substance limits, including 100 mg per kilogram combined for lead, cadmium, mercury, and hexavalent chromium, plus PFAS thresholds for food contact packaging

This is a defined annual data submission tied to waste volumes, material composition, and producer identification, not a general environmental expectation. Companies without an item or shipment level data system are working against a four week runway to the application date.

The EPR Data Readiness Scale: Where Does Your Compliance Data Stand?

Most conversations about EPR compliance treat waste data as either present or missing. In practice, companies sit somewhere on a spectrum between rough estimation and audit-ready evidence. The EPR Data Readiness Scale below gives that spectrum four defined stages, so a compliance team can name exactly where they stand today and what the next stage requires.

Stage 1: Estimated

Waste and packaging figures are reconstructed after the fact from proxies such as purchase volume or periodic sampling audits. Data cannot be traced to a specific waste stream, jurisdiction, or disposal outcome.

Stage 2: Partial

Some facilities or markets have verified figures while others still rely on estimation. Data exists but is inconsistent across the business, making a single consolidated EPR submission difficult to defend.

Stage 3: Verified

Data is captured at or close to the point of disposal, tied to a specific material, location, and reporting period, and reconcilable against the annual submissions packaging waste operators must now file under regimes like the PPWR.

Stage 4: Audit-Ready

Verified data is integrated into a single reporting workflow, linked to producer registration numbers, and structured to feed both EPR submissions and ESRS E5 disclosures without manual reconciliation between the two.

Based on the reliance on estimation-based methods described above, many companies are likely to sit at Stage 1 or Stage 2 today. The PPWR’s annual reporting requirement, and similar obligations in other jurisdictions, effectively requires Stage 3 level data, which is why closing the gap matters now, ahead of the August 12, 2026 application date.

How Can Companies Close the EPR Data Gap in Practice?

Closing this gap means moving up the EPR Data Readiness Scale one stage at a time rather than attempting to reach Audit-Ready in a single step. A practical path:

• Audit existing waste and disposal data sources across all facilities and markets to identify which are still at the Estimated stage
• Map every jurisdiction where the company has EPR obligations, since packaging, electronics, and textile rules differ in scope and reporting cadence
• Prioritize markets with the nearest binding deadlines, starting with the EU packaging obligations that take effect August 12, 2026, to move those markets from Partial to Verified first
• Replace estimation with verified data capture at the point of disposal or through processor-verified reporting
• Connect this data pipeline to existing sustainability reporting workflows to reach Audit-Ready, rather than building a separate system for EPR alone

Connecting EPR Data to ESRS E5 and Broader CSRD Reporting

The same verified disposal data that satisfies EPR reporting also feeds ESRS E5, the CSRD standard covering resource use and circular economy. ESRS E5 requires companies in scope to disclose:

• Resource inflows and outflows
• Total weight of materials leaving production processes
• Waste composition by stream and material type

One verified data pipeline can serve both obligations, removing the need to collect the same disposal figures twice, once for a national EPR authority and again for a CSRD sustainability statement. This is what Audit-Ready looks like on the EPR Data Readiness Scale: a single dataset defensible in front of both an EPR authority and a CSRD auditor. For companies navigating both regimes, this is the more direct route to compliance.

Conclusion

The circular economy does not have a materials problem. It has a visibility problem, and that visibility problem now carries real compliance deadlines. EPR laws in more than 70 jurisdictions, and the EU Packaging and Packaging Waste Regulation in particular, require the disposal and waste data most companies are still estimating rather than measuring.

Executives responsible for ESG and compliance strategy should treat this as a near-term action item:

• Identify where the business sits today on the EPR Data Readiness Scale
• Begin a waste data audit to move from Estimated toward Verified
• Connect that data to existing Scope 3 and ESRS E5 reporting workflows to reach Audit-Ready

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