Aurora Rios on what she actually sees at recycling facilities, why Extended Producer Responsibility (EPR) is the most important compliance shift for brands right now, and the moment she knew at 16 that waste would be her life’s work.
This is the eighth in a series we are calling 10 Years. 10 Lessons where BFS team members share what they actually learned from their hardest projects.
- Aurora Rios is a Hazardous Waste Specialist at BFS and a process engineer by training, specializing in wastewater and solid waste. Her engineering background shapes how she reads waste systems: she thinks in flows, inputs, and outputs, not just regulatory checklists.
- She decided she wanted to work in waste at 16. That has not changed.
- The technical challenge in waste management is rarely the treatment technology itself. System design, including how material flows are organized and what economics make recovery viable, matters far more.
- Brands operating across multiple markets are already navigating EPR obligations in the countries where it exists. As frameworks expand globally, the companies with a compliance architecture in place will move faster than those building one under pressure.
- Prevention is always cheaper, cleaner, and less risky than cleanup. This applies to waste sites exactly as it applies to any well-run operation.
- Her message to brands entering new EPR markets: the knowledge and processes already exist inside your organization. The gap is usually local execution.
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91% Of all plastic ever produced has never been recycled, a system design failure, not a technology failure Source: Science Advances / UN Environment |
400M+
Tonnes of hazardous waste are generated globally per year, with the majority in markets lacking adequate treatment infrastructure Source: UNEP Global Waste Management Outlook |
67
Countries had introduced some form of EPR legislation by 2024, expanding rapidly across Africa, LATAM & Southeast Asia Source: OECD EPR Policy Toolkit, 2024 |
Aurora, you have worked across multiple continents and very different waste contexts. What does that breadth of experience teach you about the problem?
Waste management is fundamentally the same everywhere. We are dealing with the same byproducts, the same hazardous substances, the same difficult materials. Almost every country has a cement industry that could theoretically co-incinerate certain waste types. The wheel does not need reinventing.
Where it gets complicated is infrastructure. And more specifically, the framing around recycling, which is sometimes presented as the answer to everything. Recycling is only viable when the economics work, when you can access pure enough material streams at prices that make processing worthwhile. A well-designed system creates those conditions. A poorly designed one produces material that no buyer will pay for. The conversation should start with system design, not with which treatment technology to select.
As a hazardous waste consulting specialist, what is the first thing you look for when you walk into a waste management facility?
The connection between what the facility produces and what a buyer will actually pay for.
That sounds obvious, but it breaks down regularly. A recycler processes material in a way that makes sense to them operationally, but the output does not meet the specification a downstream buyer requires. The translation between processing and value is missing. That is usually the first gap I find, and fixing it does not require new equipment. It requires better system design upstream. An engineering approach is useful here precisely because it forces the question of output specification before you design the process, not after.
The second thing I look for is input volume. For electronics in particular, informal and semi-formal trading means the material reaching formal recyclers can be inconsistent. Where there is no functioning collection system in place, securing a reliable and consistent input stream is the central operational challenge. The facilities that solve this problem, usually by building direct relationships with collectors or by anchoring their operation to a producer take-back scheme, are the ones that can run sustainably.
What I consistently see across markets is motivated people working hard against real structural constraints. Knowledgeable, well-connected within their communities, genuinely trying to build viable operations. The constraint is rarely a capability. It is usually the policy architecture that determines whether a circular model can generate enough revenue to sustain itself.
You have worked on EPR programmes across different markets. How do you think about EPR as it expands globally?
EPR is a significant structural shift in how end-of-life product management is financed. For a long time, the cost fell on public systems, municipalities, and taxpayers. EPR moves a share of that cost to producers, and it does so in a way that, when designed well, creates real incentives for better product design and better collection systems.
For brands, the practical reality is that EPR compliance is already part of operations in the markets where these frameworks exist. The processes, the reporting systems, the fee structures: a company operating in Europe has already built that muscle. As EPR frameworks expand into new markets across Africa, Latin America, and Southeast Asia, the companies that extend their existing compliance architecture rather than building from scratch in each new country will be significantly better positioned.
What I tell brands entering new EPR markets is that the knowledge is already inside their organization. The gap is usually local: understanding the specific regulation, identifying the right PRO or compliance vehicle, and connecting to a collection and treatment network that can demonstrate environmentally sound management. That is where we can help.
What do you see as the most common mistake during waste characterization or site assessment?
Two things come up repeatedly.
The first is over-sampling. Policy developers sometimes require characterization of every industrial process when a representative sample would give the same information at a fraction of the cost. We do not need to test every variation of a process to understand the hazardous waste profile it generates. The characterization phase should be designed to answer specific questions efficiently, not to cover every theoretical possibility.
The second is underestimating prevention. It is always cheaper, cleaner, and more manageable to prevent pollution than to clean it up. A proper containment review before decommissioning a site, genuine planning before any activity begins, consistently saves significant cost downstream. Engineers think in failure modes and containment by default. That instinct, applied to hazardous waste sites, is one of the most valuable things process engineering training brings to this field. This is well understood in principle and regularly underinvested in practice.
The balance that matters: do not over-engineer the characterization, and do not skip the prevention. Knowing when enough information is enough, and when early intervention pays for itself many times over, is where experience makes the most difference.
One last question. What do you want readers to take away?
I have a lot of optimism about where EPR is heading.
The expansion of producer responsibility frameworks into new markets is good for the environment, and it is also genuinely good for brands that are ready for it. Companies that already have compliance systems in place in one market carry a real competitive advantage when entering another where the regulation is arriving. They are not starting from zero. They understand the reporting requirements, the stakeholder relationships, and the operational expectations.
What I would say to any brand looking at a new market where EPR is coming: move early. The companies that engage with the regulation while it is still being designed often have real influence over how it is structured. The ones that wait until enforcement begins face a more expensive, more pressured transition.
The technical knowledge to make waste systems work exists. The policy tools are expanding. The gap is usually execution in specific markets. That is a solvable problem.
“Don’t over-engineer. Don’t neglect it either. Prevention is always cheaper, cleaner, and easier than cleanup. There is a big philosophy between life and waste.”
Aurora Rios, Hazardous Waste Specialist, BlackForest Solutions
About the series: BlackForest Solutions turns 10 in March 2026. Instead of a celebration, we asked 10 team members to share the hardest lesson from their hardest project. This is what a decade of doing the work actually looks like.
About Aurora Rios: Aurora Rios is a Hazardous Waste Specialist at BlackForest Solutions GmbH. She is a process engineer by training, specialized in wastewater and solid waste, and holds a degree from the University of Stuttgart. That engineering foundation shapes everything about how she approaches hazardous waste: she thinks in systems, in flows, in inputs and outputs, not just in compliance checklists. Her work at BFS spans waste system design, EPR programme development, hazardous waste characterization, and industrial site assessment across multiple continents. She decided at 16 that waste would be her field. It still is.
Key Concepts
EPR: Extended Producer Responsibility, a policy framework that places responsibility for end-of-life product management on manufacturers, creating financial incentives for better product design and funded collection infrastructure.
Waste characterization: The process of analyzing waste to understand its composition, hazard classification, and appropriate treatment pathway. Quality of characterization directly affects the cost and safety of downstream handling.
Co-incineration: The treatment of waste by burning it alongside fuel in industrial furnaces such as cement kilns, recovering energy while destroying hazardous content.
System design: The overall architecture of a waste management system, covering collection, sorting, treatment, and material recovery. Getting this right matters more than which specific treatment technology is selected.
PRO: Producer Responsibility Organization; the collective body through which producers manage their EPR obligations, typically funding collection and treatment infrastructure.
FAQs: EPR Compliance, Waste System Design & Hazardous Waste in Emerging Markets
Q1. What is waste system design, and why does it matter more than treatment technology?
Waste system design is the overall architecture of how material flows are collected, sorted, processed, and recovered, including the economic logic that makes each step viable. Treatment technology selection only works when the upstream system produces material at the specification and volume a buyer will actually pay for. Without that architecture, even the most advanced treatment equipment processes material that has no market.
Q2. What is EPR (Extended Producer Responsibility) and how does it affect brands in emerging markets?
EPR is a regulatory framework that places the cost and responsibility for end-of-life product management on producers rather than on public waste systems. As EPR frameworks expand into Africa, Latin America, and Southeast Asia, brands that already operate under EPR in Europe or North America can extend their existing compliance architecture reporting systems, fee structures, and PRO relationships rather than building from scratch in each new market.
Q3. What is a Producer Responsibility Organization (PRO) and how does it work?
A PRO is a collective body through which producers meet their EPR obligations without managing collection and treatment infrastructure individually. Producers pay fees into the PRO, which contracts with collection and treatment operators, manages reporting to regulators, and ensures that the required volumes of material are recovered in an environmentally sound way. Choosing the right PRO in a new market is one of the most consequential early decisions a brand entering that market must make.
Q4. What are the most common mistakes made during hazardous waste characterization?
Two errors appear repeatedly. The first is over-sampling, commissioning characterization of every industrial process variation when a representative sample would answer the same questions at a fraction of the cost. The second is underinvestment in prevention: skipping containment review before site decommissioning, or delaying hazard assessment until cleanup is already required. Prevention consistently costs less than cleanup, often by an order of magnitude.
Q5. How does an engineering approach change how you assess a waste management facility?
An engineering lens focuses on outputs before processes: what specification does a downstream buyer require, and does the facility’s processing produce material that meets it? This reframes facility assessment from a compliance checklist exercise into a systems-flow analysis, revealing where value is being destroyed rather than just where rules are being broken. It also highlights the input-volume problem, whether the facility has a reliable, consistent feedstock, which determines operational sustainability.
Q6. What is co-incineration, and when is it used in hazardous waste management?
Co-incineration is the treatment of waste by burning it alongside fuel in high-temperature industrial furnaces, most commonly cement kilns. It destroys hazardous content while recovering the energy value of the waste, and it is available in most countries that have a cement industry. Aurora Rios notes that this treatment pathway is often overlooked in markets where it is already technically available and where other hazardous waste infrastructure is absent.
Q7. What should brands do to prepare for EPR regulation arriving in a new market?
Move before enforcement begins. Brands that engage with EPR regulation during the design phase often have real influence over how frameworks are structured, which fee models, which material categories, and which PRO structures are written into law. Those who wait until enforcement begins face a more expensive, more compressed transition. Aurora Rios’ consistent advice: the knowledge already exists inside most organizations that operate in regulated markets; the gap is local execution.