Last updated: May 2026. The Philippines Extended Producer Responsibility law is now an active compliance requirement for large enterprises that generate plastic packaging waste. For covered companies, EPR is no longer only a sustainability initiative. It affects packaging data, recovery programs, third-party audit evidence, annual reporting, and potential penalties.
Short answer: Republic Act No. 11898, or the Extended Producer Responsibility Act of 2022, requires obliged enterprises to establish EPR programs for plastic packaging, recover or offset a rising share of their plastic packaging footprint, and submit documented compliance reports supported by independent third-party audit. The recovery target is 50% for the footprint generated in 2025, 60% for 2026, 70% for 2027, and 80% from 2028 onward.
What is the EPR law in the Philippines?
The Extended Producer Responsibility Act of 2022, formally Republic Act No. 11898, amended the Ecological Solid Waste Management Act of 2000. It introduced a mandatory EPR mechanism for plastic packaging waste and made certain producers responsible for the post-consumer stage of packaging they place on the market.
In practical terms, the EPR law asks covered companies to move from voluntary cleanup or recycling activities to a registered and measurable program. The company needs to understand its plastic packaging footprint, define how it will recover or divert plastic packaging waste, maintain documentation, and report performance.
Who needs to comply with RA 11898?
The law mainly applies to large enterprises that generate plastic packaging waste. A large enterprise generally means a business whose total assets exceed the medium-enterprise threshold under the MSME framework, excluding the land on which the business' office, plant, or equipment is situated. The commonly referenced threshold is assets above PHP 100 million.
Covered producers can include brand owners, manufacturers, and importers. MSMEs are generally not covered, but the law can still capture related enterprises carrying the same brand, label, or trademark if their combined assets exceed the threshold. MSMEs are also encouraged to participate voluntarily or join networks of obliged enterprises and producer responsibility organizations.
| Company type | Likely EPR status | What to check first |
|---|---|---|
| Large brand owner selling goods under its own brand | Potentially obliged | Total assets, brands, plastic packaging types, annual footprint |
| Importer of consumer goods sold in the Philippines | Potentially obliged | Whether goods enter the market in original or repackaged plastic packaging |
| Manufacturer producing for another obliged brand owner | Depends on the arrangement | Who owns the brand and who is treated as the product producer for EPR purposes |
| MSME | Usually not mandatory, but voluntary participation encouraged | Whether related companies using the same brand cross the large-enterprise threshold |
What plastic packaging is covered?
RA 11898 focuses on plastic packaging used to carry, protect, or pack goods for transportation, distribution, and sale. Covered packaging includes flexible and rigid plastic formats, plastic bags, and polystyrene.
- Sachets, labels, laminates, and other flexible plastic packaging, including multi-layer packaging
- Rigid plastic packaging such as containers, caps, lids, and similar packaging components
- Plastic bags used to carry or transport goods at the point of sale
- Polystyrene packaging
The first practical task is to map packaging by material type, brand, product line, and quantity. Without this footprint, it is difficult to set the recovery target, work with a PRO, or prepare the annual compliance file.
EPR recovery targets in the Philippines
The EPR law phases in recovery or offset targets for the plastic product footprint generated during the immediately preceding year. These targets rise over time until they reach 80% from 2028 onward.
| Compliance date | Recovery or offset target | Practical meaning |
|---|---|---|
| 31 December 2023 | 20% | First statutory recovery target |
| 31 December 2024 | 40% | Second-year target |
| 31 December 2025 | 50% | Current near-term target for companies preparing 2025 performance files |
| 31 December 2026 | 60% | Next step-up in the target |
| 31 December 2027 | 70% | Final transition year before the full ongoing target |
| 31 December 2028 and every year after | 80% | Ongoing recovery or offset expectation |
What does an EPR program need to include?
An obliged enterprise can implement an EPR program individually, collectively, or through a Producer Responsibility Organization. The program should connect the company's plastic packaging footprint to concrete recovery, reuse, recycling, diversion, redesign, and documentation activities.
Common EPR program elements include:
- Information on the obliged enterprise or PRO and the person responsible for EPR
- The covered packaging materials and product brands
- The implementation route: individual, collective, or through a PRO
- Verifiable volume or weight of plastic packaging placed on the market
- Target volume or weight for recovery, reuse, recycling, or diversion
- Packaging redesign or reduction initiatives
- Packaging labels that help with recovery, reuse, recycling, or proper disposal
- Status of EPR implementation and compliance
Annual reporting and independent audit
RA 11898 requires obliged enterprises or their PROs to submit annual compliance reports. The law also requires an independent third-party auditor to certify the veracity of the reported plastic product footprint, recovery data, and EPR program compliance.
DENR Administrative Order No. 2024-04 introduced compliance reporting and audit guidelines for the EPR Act. In practice, companies should expect to prepare an EPR compliance file that includes footprint calculations, recovery evidence, program documentation, and auditor-ready supporting records.
The key point for internal teams is that EPR reporting is not only a narrative sustainability report. It is a data-backed compliance exercise. Procurement, packaging, sales, logistics, finance, sustainability, legal, and external recovery partners may all need to contribute evidence.
What happens if an obliged enterprise does not comply?
The EPR Act includes significant penalties for failure to register an EPR program or failure to meet the required recovery targets. The law provides fines of PHP 5 million to PHP 10 million for a first offense, PHP 10 million to PHP 15 million for a second offense, and PHP 15 million to PHP 20 million for a third offense, with automatic suspension of business permit until compliance for the third offense.
If a company fails to meet the recovery target, the penalty can be the statutory fine or twice the cost of recovery and diversion of the plastic footprint or shortfall, whichever is higher. This makes early packaging data and recovery planning commercially important, not just administratively useful.
How companies should prepare
A clean EPR response starts with the actual packaging footprint and the company's legal status. Before preparing claims or reports, companies should confirm whether they are an obliged enterprise, which brands and entities are in scope, which packaging materials are covered, and which evidence will be needed for audit.
- Confirm applicability. Check entity size, brand ownership, importer/manufacturer role, and whether related entities using the same brand affect coverage.
- Map packaging. Build a packaging inventory by material type, product line, brand, volume, weight, supplier, and market channel.
- Calculate the plastic packaging footprint. Use a defensible method and keep source records.
- Set the recovery path. Decide whether to implement directly, collectively, or through a PRO.
- Collect evidence. Keep recovery, transport, recycling, diversion, partner, and audit records organized from the start.
- Prepare annual reporting. Align the compliance report, audit trail, and supporting documentation before deadlines become urgent.
- Review penalties and risk. Identify target gaps early enough to close them through recovery, diversion, redesign, or partner action.
How Keslio can help
Keslio helps companies turn EPR requirements into a practical compliance and sustainability workstream. We can support packaging data collection, footprint calculations, reporting structure, supplier and recovery-partner coordination, and documentation for management review or external audit.
For companies that are still unsure where to start, Keslio can first review whether the EPR law appears relevant to the company, identify the likely data gaps, and scope a focused support project instead of turning EPR into a broad sustainability strategy exercise.
