As illustrated by the case studies of end-of-life vehicles and waste electric and electronic equipment, the approach of an extended producer responsibility is undermined by the exports of used and waste products. This fact causes severe deficits regarding circular flows, especially of critical raw materials such as platinum group metals. With regard to global recycling there seems to be a responsibility gap which leads somehow to open ends of waste flows and a loss or down-cycling of potential secondary resources. Existing product-orientated extended producer responsibility (EPR) approaches with mass-based recycling quotas do not create adequate incentives to supply waste materials containing precious metals to a high-quality recycling and should be amended by aspects of a material stewardship. The paper analyses incentive effects on EPR for the mentioned product groups and metals, resulting from existing regulations in Germany. It develops a proposal for an international covenant on metal recycling as a policy instrument for a governance-oriented framework to initiate systemic innovations along the complete value chain taking into account product group-and resource group-specific aspects on different spatial levels. It aims at the effective implementation of a central idea of EPR, the transition of a waste regime still focusing on safe disposal towards a sustainable management of resources for the complete lifecycle of products.