Summary
Details
- Philippines
Covered large enterprises must:
Establish an EPR program.
Register.
Measure their plastic packaging footprint.
Meet annual recovery targets.
Maintain supporting evidence.
Obtain required independent verification.
Submit compliance reports.
Micro, small and medium enterprises are not generally subject to the same mandatory large-enterprise obligations, although voluntary participation is encouraged.
Deep dive
- What’s Required
- 1. Determine whether the company is an obliged enterprise
- 2. Establish an EPR program
- 3. Recover plastic packaging waste
- 4. Use recognized recovery strategies
- 5. Register the EPR program
- 6. Implement independent compliance auditing
- 7. Submit compliance reports
- 8. Account for the plastic packaging footprint
- Important Deadlines
- Current Status
- Penalties for Non-Compliance
- Examples of Known Violations / Failure Modes
- Resources
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What’s Required
1. Determine whether the company is an obliged enterprise
The law primarily targets large enterprises placing plastic packaging on the Philippine market.
Covered companies must assess:
Enterprise size.
Plastic packaging footprint.
Product portfolio.
Imported packaging.
Applicable corporate structure.
2. Establish an EPR program
Obliged enterprises must establish and implement an EPR program for their plastic packaging.
A company can:
Implement the program individually.
Participate collectively.
Join a Producer Responsibility Organization.
3. Recover plastic packaging waste
The law establishes minimum recovery targets based on the company’s plastic packaging footprint.
Targets are:
Compliance year | Minimum recovery |
|---|---|
2023 | 20% |
2024 | 40% |
2025 | 50% |
2026 | 60% |
2027 | 70% |
2028 onward | 80% |
4. Use recognized recovery strategies
EPR programs may involve measures such as:
Waste reduction.
Product redesign.
Reuse.
Collection.
Recycling.
Recovery.
Treatment.
Proper disposal.
Plastic offsetting where permitted by the regulatory framework.
5. Register the EPR program
Obliged enterprises must register their EPR programs with the Department of Environment and Natural Resources.
6. Implement independent compliance auditing
The framework requires an auditing system for monitoring and assessing EPR compliance.
Compliance information must be supported by an independent third-party auditor under the standards established by DENR.
7. Submit compliance reports
Obliged enterprises must demonstrate achievement of their annual diversion and recovery obligations through required reports and audited evidence.
8. Account for the plastic packaging footprint
The EPR program is based on quantification of plastic packaging placed on the market.
Companies therefore need reliable information on:
Packaging type.
Packaging weight.
Product sales.
Imports.
Waste recovered.
Recycling or treatment route.
Important Deadlines
July 23, 2022: Republic Act No. 11898 became law.
January 2023: DENR issued implementing rules and regulations.
End of 2023: Initial 20% plastic recovery target.
2024: 40% target.
2025: 50% target.
2026: 60% target.
2027: 70% target.
2028 onward: 80% annual recovery target.
Current Status
Active and legally binding.
The law remains a core part of Philippine circular economy and plastic waste policy.
DENR continues to identify Republic Act 11898 as the national EPR framework for large companies managing plastic packaging waste.
For 2026, obliged enterprises are working against the statutory 60% recovery target.
Penalties for Non-Compliance
Failure to comply can trigger penalties under Republic Act 11898 and the amended Ecological Solid Waste Management Act.
Possible consequences include:
Administrative fines.
Regulatory enforcement.
Orders to correct non-compliance.
Compliance scrutiny.
Reputational consequences.
Potential loss of fiscal or program benefits.
Exact sanctions depend on the violation, its recurrence, and the relevant implementing provisions.
Examples of Known Violations / Failure Modes
Failing to register an EPR program.
Underreporting the plastic packaging footprint.
Missing the annual recovery target.
Counting unsupported waste recovery.
Double counting recovered plastic.
Using unverified recycling or disposal evidence.
Failing to obtain independent audit verification.
Incorrectly classifying an enterprise as exempt.
Omitting imported packaging.
Failing to submit required reports.
Using recovery activities outside permitted EPR methods.
Treating participation in a voluntary recycling initiative as equivalent to statutory EPR compliance.
Resources
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