Eco-modulation as a driver for eco-design: a dynamic view of the French collective EPR scheme

Extended Producer Responsibility (EPR) systems have been criticized to provide little incentive forproducers to eco-design. To this end, an incentive scheme, called eco-modulation, based on modulatedproduct fees according to their level of eco-design has recently been introduced. This paper provides acomprehensive analysis of the introduction of this scheme as part of the collective EPR system in theWEEE sector in France and discusses the impacts of this policy instrument on product design (directeffects) and collective action and innovation (indirect effects). From a theoretical standpoint, we considerpolicy instruments in our research as part of complex policy mixes and within adaptive policy-making,i.e. on how these mixes evolve over time to adapt to complex and changing issues and collective dy-namics. In this perspective, we stress that, while eco-modulation has shown little direct impact,important indirect effects can be identified. We argue that framework conditions, i.e. how the EPRsystem is organized and conducted in practice, explain better the occurrence of such indirect effectsrather than the policy instrument in itself. In this perspective, the paper provides insights on the role ofProducer Responsibility Organizations (PRO) in linking individual and collective producer responsibilitiesand organizing collective action. Moreover, it shows that implementing such a policy instrument requiresintense dialog with stakeholders to advance its acceptability, a collective organization to organize itsmonitoring and deployment, and careful integration with other instruments within a coherent andadaptive policy.