Reforming Extended Producer Responsibility (EPR) for Packaging

Current legislation provides that where goods are produced in packaging, the manufacturer is responsible for the disposal of the packaging. This entails high administrative costs and makes monitoring the large number of producers of packaged goods impossible. What are the pros and cons of shifting EPR from goods manufacturers to packaging manufacturers? Under which conditions can associations of goods and packaging manufacturers remain subjects of EPR? What should the operating principles of associations be to make EPR more effective? Opportunities to include in legislation a mechanism that would exempt subjects of EPR from the administrative liability that arises in connection with the actions of an unscrupulous operator.