28/08/2026
Is Your Business Affected by Extended Producer Responsibility (EPR)?
“But we don't manufacture the product.” It is one of the most common assumptions businesses make when they first encounter EPR. But here is the more important question: Does your business place a product covered by EPR on the South African market?
The answer may determine whether EPR applies to your organisation. Under South Africa's EPR framework, the concept of a producer extends beyond the company that physically manufactures a product. Depending on the product category and circumstances, it can include manufacturers, importers, brand owners and, in certain cases, retailers and other businesses involved in placing products on the market.
This is an important distinction. A company may not manufacture a product itself, but if it imports it, sells it under its own brand, or otherwise plays a role in placing a covered product on the South African market, it may have responsibilities under the EPR framework.
Where do businesses often get it wrong?
There is a tendency to view EPR as something that sits solely with manufacturers or something that can be dealt with once a compliance deadline approach. In practice, determining EPR responsibility requires a closer look at the organisation's products, supply chain, market activities and data.
Effective EPR management starts with knowing what you place on the market, what is within scope, what your obligations are, and who is responsible for managing them. Without clear ownership and reliable data, compliance can quickly become reactive
At TOMA-Now, our experience in the EPR space has shown us that effective compliance requires more than simply understanding the regulations. It requires organisations to translate those requirements into practical systems, responsibilities and strategies. Our work has included supporting Pepkor Holdings with its EPR compliance journey, including the development of a compliance roadmap and approaches to managing EPR-related data and obligations.
This experience reinforces an important lesson:
EPR compliance should not start when the deadline arrives. It should start with understanding your position.
📦 What are you placing on the market?
🏢 What is your role?
♻️ What products are within scope?
📊 What information do you have?
⚖️ And what responsibilities follow?
Answering these questions early allows businesses to move from reactive compliance to proactive EPR management while identifying opportunities to improve resource efficiency, packaging decisions and broader circular economy performance.
Follow TOMA-Now as we continue unpacking EPR and the practical steps businesses can take towards a more sustainable and resource-efficient future.
