Recycling, reuse, and reduction of exhaustible resources has become a major goal in developed economies, which entails the active participation of producers. The implementation of Extended Producer Responsibility, whereby firms are financially responsible for their products' end-of-life costs, is commonly delegated to a Producer Responsibility Organisation (PRO). PROs are playing a crucial role in the development of a circular economy. PROs finance collection, sorting and recycling of waste by collecting fees from producers that are subject to EPR. These fees should reflect waste management costs and consequently influence producers on their product design and material use. Hence PRO pricing behaviour can influence the whole recycling program and production. We propose a theoretical model where downstream material flows and waste management are delegated to a PRO in order to study the efficiency of this dominant industry organisation. The analysis allows to address the key policy questions and provides guidance for the design of EPR programs.