EPR Scheme

Cambodia has a growing waste problem with more than four million tons of garbage produced per year according to the country’s Ministry of Environment (MoE). This amount is estimated to be growing by 10 to 12 % every year. When it comes to plastic bottles specifically, the amount of waste generated is also estimated to be rising dramatically every year, driven by a rising middle class and ensuing consumerist lifestyles, together with the recurring lack of recycling and circular economy options. Cambodia has still not put in place a comprehensive recycling and/or circular economy system.

This means that most, if not all, of the plastic bottles consumed in Cambodia do not have formal recycling options. The only capillary recycling option offered at the moment in Cambodia, particularly in the capital Phnom Penh, is thanks to informal waste collectors who drift around city streets night and day collecting items from household waste and selling them on to larger waste collectors.

Notably, Cambodia’s private sector, the largest contributor of plastic bottle waste as the seller of beverages, is not present enough in providing recycling and/or circular economy solutions, despite encouraging recent progress on testing solutions such as manuals for hotels and water dispensers to reduce the use of plastic bottles. Particularly when considering best practices offered in other developing countries, the private sector needs to be more involved in providing environmentally-friendly solutions to alleviate the creation of plastic bottle waste in Cambodia’s countryside, streets, waterways, and streets. One such solution, already tested and implemented in many countries worldwide, is an Extended Producer Responsibility (EPR) scheme.

An EPR scheme is an environmental policy that makes producers responsible for the entire life cycle of the products that they introduce to the market, from their design until end-of-life (including waste collection and recycling). Under the scheme, liable companies must mitigate the environmental impacts of their products throughout the entire product life cycle, thus providing a valid circular economic alternative to the single use of bottles. This responsibility provides an incentive to reduce waste at the source and promote product design for the environment.

In March 2025, MOE issued Prakas No. 2196/0325 on the liabilities of exclusive electrical and electronic manufacturers, importers, and suppliers for the collection and disposal of electrical and electronic waste (e-waste). The Prakas introduces a mandatory extended producer responsibility scheme, requiring these entities to collect, manage, and process e-waste generated from their products after use or disposal. Manufacturers, importers, and suppliers must report the quantities and types of electrical and electronic products imported, as well as e-waste collected, on a semi-annual basis. E-waste must be treated by a licensed waste management company or re-exported to its country of origin.

EuroCham welcomes this as a significant step towards developing robust EPR schemes in Cambodia, but notes that additional EPR mechanisms should be adopted for product categories beyond electrical and electronic waste, which should be under a holistic EPR scheme.

The absence of a mandatory EPR scheme creates an uneven playing field for businesses. Companies that wish to implement recycling and responsible end-of-life management face limited formal recycling options, as most waste service providers focus on collection and disposal rather than actual recycling, while the informal sector cannot provide traceability or reliable reporting. This makes credible recycling difficult and costly to implement.

As a result, responsible companies must finance their own recycling arrangements and reporting systems, increasing operational costs that are not borne by competitors who do not adopt similar practices. This places an unfair burden on the formal economy and discourages voluntary compliance. At the same time, the lack of a national EPR framework limits companies’ ability to make credible sustainability claims and exposes brands to reputational risks from visible plastic pollution. Without mandatory EPR for all producers, sustainability becomes a competitive disadvantage rather than a shared responsibility.