New EPR Regulations: Impact on Plastic Bag Producers

March 19, 2025

Introduction:

The recently issued Prime Ministerial Decree No. 662 of 2025 (the “Decree”) introduces new regulations under the Extended Producer Responsibility (“EPR”) framework for plastic shopping bags. Published in the Official Gazette on 2 March 2025, the Decree mandates that producers and importers of plastic shopping bags comply with specific environmental and financial obligations aimed at reducing plastic waste and promoting sustainable waste management practices. The Decree will take effect three (3) months after its publication in the Official Gazette.

EPR is an environmental policy that holds producers accountable for the entire lifecycle of their products, including the costs associated with their waste management. This policy was initially incorporated into the Waste Management Law No. 202 of 2020 (the “Waste Management Law”), pending the issuance of a Prime Ministerial Decree to clarity its application.

Scope:

The Decree applies to all producers and importers of plastic shopping bags that conform to Egyptian Standard Specification No. 2004. These bags are now classified as priority products subject to Clause 17 of Waste Management Law under the EPR framework.

Obligations:

    • Producers and importers of plastic shopping bags must register on the National Waste Management Information System’s website. A quarterly report detailing the quantities of plastic shopping bags sold must be submitted on the same platform, including the total weight of bags sold during the quarter.
    • Producers and importers of plastic shopping bags must pay a fee of EGP 37.5 per kilogram of plastic shopping bags sold in the local market. This fee is intended to cover the costs of the safe disposal of plastic waste by the relevant authorities. The collected fees will be deposited into the Waste Management Regulatory Agency’s account to fund safe disposal initiatives and other waste management programmes.
    • The Agency is required to submit an annual report to the Council of Ministers detailing the outcomes of the Decree’s implementation.

    Implications:

    Producers and importers of plastic shopping bags must ensure compliance with the new registration, reporting, and financial obligations. They must also review their products to ensure they meet the Egyptian Standard Specification No. 2004.

    While the imposed fees may lead to increased costs for businesses, potentially passed on to consumers, EPR policies remain a powerful tool for sustainable waste management. Such policies promote waste reduction, cost efficiency, and improved product design on a global scale.  

    Conclusion:

    The new Decree marks an initial step in the implementation of the EPR policy in Egypt. While its current scope is limited, it establishes a foundation for the gradual expansion of EPR policies in the future.

      For further assistance or clarification on how these regulations may impact your operations, please contact our Energy, Environment, and Natural Resources (EENR) Practice Group:

      Malak Khalil, Partner and Head of EENR

      Sadeem Abdelsalam, Managing Associate

      Taya Pirinis, Managing Associate

      Disclaimer:

      This client alert is for informational purposes only and does not constitute legal advice. Please consult with qualified legal counsel for advice on specific legal issues.

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