In 2023, the Philippines enacted one of the world’s most ambitious laws on Extended Producer Responsibility (EPR), requiring companies with at least ₱100 million in assets to take responsibility for an increasing percentage of their plastic footprint. The law mandates that these Obliged Enterprises recover and divert a portion of their plastic packaging waste, starting at 20 percent in 2023 and rising to 80 percent by 2028. For a country that is one of the world’s largest contributors of marine plastic litter, this law represents a significant structural shift in how waste is managed — moving the burden from local governments and consumers onto the producers themselves.
These numbers suggest early momentum. The Department of Environment and Natural Resources’ Environmental Management Bureau reported that as of August 2024, 947 companies had registered an EPR program, enabling the recovery and diversion of 163,000 metric tons of post-consumer plastic packaging waste in the law’s first year. While not all Obliged Enterprises complied initially, the majority of the largest plastic packaging producers met or exceeded the minimum 20 percent recovery target. That pattern — large producers leading compliance — is worth noting because it suggests the law’s design aligns with the capabilities of the companies best positioned to absorb new costs and logistics. The question is whether that momentum can scale to meet the 80 percent target by 2028, especially given the Philippines’ fragmented waste management infrastructure and the prevalence of the sachet economy, where brands deliver goods in small, affordable units that generate disproportionate plastic waste.
How the EPR law works and what it requires
The law’s structure is straightforward but ambitious. It applies to companies with at least ₱100 million in assets — a threshold that captures most major consumer goods and retail firms. These Obliged Enterprises must register an EPR program with the DENR and meet annual recovery targets for their plastic packaging waste. The targets escalate sharply: 20 percent in 2023, 40 percent in 2024, 50 percent in 2025, 60 percent in 2026, 70 percent in 2027, and 80 percent in 2028.
To meet these targets, companies can choose from a menu of measures. Six upstream actions focus on reducing plastic use at the design stage — using recycled content, switching to reusable packaging, or eliminating unnecessary packaging altogether. Six downstream actions focus on recovering plastic after it becomes waste, and one of the most notable is plastic crediting, a market-based mechanism that allows companies to fund the cleanup of plastic waste beyond their own supply chain. As Nanette Medved-Po, Founder of PCX Markets and PCX Solutions, put it, plastic credits can play a pivotal role in supporting EPR laws, particularly in emerging markets that lack collection and recycling systems. This flexibility is intentional — it acknowledges that the Philippines does not yet have the infrastructure to handle the volume of plastic waste it generates, so the law creates a financial incentive for the private sector to help build that infrastructure.
Early results and the gaps that remain
The first year of implementation produced measurable results, but also revealed where the system still falls short. The 163,000 metric tons recovered in 2023 is a tangible achievement, but it represents only a fraction of the total plastic waste generated annually in the Philippines. A case study published by PCX Solutions, titled “Extended Producer Responsibility in the Philippines: Early Learnings and Insights for Emerging Markets Battling Plastic Pollution,” notes that while the majority of large plastic producers complied, not all Obliged Enterprises did. The report also identifies several significant milestones still to unlock: dealing with decades of legacy plastic pollution, creating policies that stimulate both supply and demand for recycled materials, reducing and eliminating unnecessary plastic packaging, and establishing national standards for transparency and accountability.
One of the most persistent challenges is the sachet economy. In the Philippines, many consumer goods — shampoo, coffee, detergent, cooking oil — are sold in single-use sachets because they are affordable for low-income households. These sachets are typically made of multi-layered plastics that are difficult and expensive to recycle. The EPR law does not ban sachets, but it does require producers to account for them in their recovery targets. That means companies must either redesign their packaging to be more recyclable or pay for the collection and processing of sachet waste — a cost that may ultimately be passed on to consumers. This tension between affordability and environmental responsibility is central to the debate around the law’s effectiveness.
Another dimension that often gets overlooked is the social impact of plastic regulation. The Gender Equity and Social Inclusion (GESI) assessment, supported by the UK Government and presented through the National Plastic Action Partnership (NPAP) Philippines, found that the impacts of plastic pollution are not evenly distributed. Vulnerable groups — especially women and informal waste workers — bear a disproportionate burden despite playing a central role in waste management systems. Women are often at the frontlines of informal waste collection and sorting, yet they face persistent systemic barriers, including lack of formal recognition, low wages, and unsafe working conditions. Lloyd Cameron, Economic and Climate Counsellor from the British Embassy Manila, noted that when formalising the waste economy, the specific barriers faced by women must be understood and addressed to ensure the transition is just and inclusive.
The table below summarises the key stakeholder groups affected by the EPR law and the specific challenges they face:
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| Stakeholder Group | Role in Plastic Value Chain | Key Challenge |
|---|---|---|
| Women (informal waste workers) | Collection, sorting, community recycling | Lack of formal recognition, low wages, unsafe conditions |
| Informal waste workers (general) | Primary collectors of recyclable materials | Exclusion from formal waste systems, health risks |
| Local government units | Waste management and disposal | Limited budgets, fragmented infrastructure |
| Obliged Enterprises | Product and packaging producers | Compliance costs, redesign of packaging, supply chain logistics |
What critics say and where the law falls short
Despite the early compliance numbers, critics point to several structural weaknesses in the EPR law. One of the most frequently cited issues is the lack of a nationwide ban on single-use plastics. While 489 cities and towns have enacted local bans on plastic bags, there is no national legislation prohibiting single-use plastics. This patchwork of local ordinances creates confusion for businesses operating across multiple jurisdictions and makes enforcement inconsistent. A national single-use plastic ban has been proposed and has been pending for several years, but it has not yet passed.
Another concern is the reliance on plastic crediting as a compliance mechanism. While plastic credits can fund cleanup projects and infrastructure development, critics argue that they allow companies to continue producing plastic waste without fundamentally changing their packaging design. In other words, a company could meet its EPR targets by paying for the collection and recycling of plastic waste elsewhere, rather than reducing the amount of plastic it puts into the market. This is not necessarily a flaw — the law is designed to be flexible — but it does raise questions about whether the system will drive genuine reductions in plastic production or simply create a market for offsets.
The just transition for single-use plastic workers is another area where the law has been criticised. A study published in The Economic and Labour Relations Review highlights that while a national SUP ban would be a significant step forward in mitigating plastic pollution and climate change, it would also have economic and employment impacts on firms and workers. The study fills a gap by examining how workers in the single-use plastic industry — many of whom are low-income and lack formal employment protections — would be affected by a transition away from plastic production. The EPR law does not include specific provisions for retraining, social safety nets, or alternative livelihood programs for these workers, which critics say is a significant oversight.
There is also the question of enforcement capacity. The DENR’s Environmental Management Bureau is responsible for monitoring compliance, but it has limited resources and personnel to audit hundreds of companies across a country of more than 7,600 islands. The PCX Solutions report acknowledges that national standards to establish transparency, credibility and accountability are still needed. Without robust monitoring and enforcement, there is a risk that some companies will underreport their plastic footprint or fail to meet their recovery targets without consequence.
What businesses and consumers should know
For businesses that fall under the EPR law, the first step is straightforward: register an EPR program with the DENR if you have not already done so. The deadline for registration has passed, but companies that missed it should still register as soon as possible to avoid penalties. The next step is to assess your plastic footprint — that is, the total volume and type of plastic packaging your company puts into the market. This baseline measurement is essential for setting recovery targets and choosing which upstream or downstream measures to pursue.
Choosing compliance measures
Companies have options. If your packaging is already recyclable or reusable, you may be able to meet your targets through upstream measures like switching to recycled content or eliminating unnecessary packaging. If your packaging is difficult to recycle — as is the case with multi-layered sachets — you will likely need to invest in downstream measures, such as funding collection and recycling programs or purchasing plastic credits. The key is to start early, because the targets escalate quickly. A company that meets the 20 percent target in 2023 will need to recover 80 percent of its plastic packaging by 2028 — a fourfold increase in just five years.
Understanding plastic credits
Plastic credits are a market-based mechanism that allows companies to fund the collection and recycling of plastic waste beyond their own supply chain. They work similarly to carbon credits: a company pays a verifier (such as PCX Solutions) to certify that a certain amount of plastic waste has been collected and processed, and the company receives a credit that counts toward its EPR target. This is particularly useful for companies whose packaging is difficult to recycle or who operate in areas with limited waste infrastructure. However, plastic credits should be seen as a complement to — not a substitute for — reducing plastic use at the source.
What consumers can do
While the EPR law places the primary responsibility on producers, consumers still play a role. Choosing products with minimal or recyclable packaging, supporting brands that have registered EPR programs, and participating in local recycling initiatives all help build the demand side of the circular economy. The law also creates an opportunity for consumers to hold companies accountable: if a brand’s packaging is not being recovered, that information should eventually become public through DENR reporting.
Emerging developments: the National Plastic Action Roadmap
The NPAP Philippines is currently finalising a National Plastic Action Roadmap, a strategic framework aimed at accelerating coordinated action to address plastic pollution and advance circularity. This roadmap is being shaped by insights from the PlastiBASE study (which explores how plastic pollution affects ecosystems and communities) and the GESI assessment. It is expected to provide more detailed guidance on how the EPR law will be implemented, including standards for transparency, social inclusion, and biodiversity protection. Businesses and local governments should monitor the roadmap’s release, as it will likely introduce new reporting requirements and best practices.
Frequently asked questions about the Philippine EPR law
Which companies are required to comply with the EPR law? ▾
What happens if a company does not meet its recovery target? ▾
Does the EPR law ban single-use plastics? ▾
How are plastic credits verified? ▾
What is the role of informal waste workers under the EPR law? ▾
Can small businesses participate voluntarily? ▾
What to watch for next
The Philippine EPR law is still in its early stages, and its long-term impact will depend on several factors: whether enforcement keeps pace with the escalating targets, whether the National Plastic Action Roadmap provides clear standards for transparency and social inclusion, and whether the private sector continues to invest in collection and recycling infrastructure. The early compliance numbers are encouraging, but they represent the low-hanging fruit. The real test will come in 2026 and 2027, when the targets reach 60 and 70 percent — levels that will require significant investment in systems that do not yet exist at scale. For now, the law has done something important: it has started a conversation, created a framework, and put the responsibility where it belongs. If this was useful, you might also want to read how local communities are tackling pollution on their own terms.
Sources
Fighting waste: the Philippines’ solid waste struggle — A deeper look at the country’s waste management challenges and the infrastructure gaps that the EPR law aims to address.
PCX Solutions Report Shows Philippines’ New EPR Law Making an Impact on Plastic Pollution. PCX Markets, 2024.
From data to action: New studies gather cross-sector insights to guide Philippines’ plastic action roadmap. UNDP Philippines, 2024.
The challenge of just transition for single-use plastic workers in the Philippines. The Economic and Labour Relations Review, Cambridge University Press.
