Philippines Develops Compliance Reporting and Audit Guidelines for the Extended Producer Responsibility (EPR) Act

In May 2024, the Philippines Department of Environment and Natural Resources (DENR) unveiled Administrative Order No. 4 of 2024 regarding Compliance Reporting and Audit Guidelines for Republic Act No. 11898 or the Extended Producer Responsibility Act of 2022.

This new Order is promulgated to provide guidance and templates to Obliged Enterprises (OEs), Collectives, and Producer Responsibility Organizations (PROs), as well as their respective independent third-party EPR compliance auditors for the submission of annual EPR Compliance Audit Report (ECAR) before the release of uniform audit standards. The ECAR is consisted of both the EPR Compliance Report (ECR) and the Audit Report.

EPR Compliance Report (ECR) 

All registered OEs, Collectives and PROs shall prepare their annual ECR including the followings:

• Name of the registered OE, Collective and PRO and their EPR registration number;

• Reference Year, i.e., the calendar year the report covers;

• Summary of Accountable Plastic Footprint;

• Summary of Accounted Plastic Waste Diverted;

• Plastic Waste Diversion Accomplishment;

• Other voluntary disclosures.

A sample ECR is provided in Annex A of this order.

EPR Compliance Audit Report 

OEs, Collectives and PROs shall engage an independent third-party auditor to certify the veracity of the reported plastic product footprint generation, recovery, and EPR program compliance. The conduct of the compliance audit should include an Audit Report, based on the Agreed-Upon Procedures (AUP) with the DENR, Limited Assurance or Reasonable Assurance. The samples of AUP report, Limited Assurance report and Reasonable Assurance report is provided in Annex B, C, and D, respectively.

Specifically, the audit checklist for the OEs based on AUP include the followings:

• General requirements: the auditor should obtain a copy of a duly signed ECR, EPR program and supporting documents;

• Verification of the Summary of Accountable Plastic Footprint;

• Verification of the Summary of Plastic Waste Diverted;

• Verification of the Plastic Waste Diversion Accomplishment.

EPR Compliance Audit Report (ECAR) 

The ECAR submitted by the OEs, PROs or Collectives should consist of the followings:

• An independent third-party audit report;

• The duly notarized ECR.

Deadline for the ECAR submission shall be June 30 or the first working day immediately thereafter.

EPR Compliance Reporting and Audit Framework 

As mentioned above, the overall framework of EPR compliance reporting and audit can be summarized as the chart below: