The strategy adopted for the implementation of the extended producer responsibility (EPR) in the State of São Paulo was conceived in three phases, the first and second of which have already been completed, while the third is in progress. The aim of this paper is to evaluate the response of EPR systems to the advancement of regulation, based on the case study of waste electrical and electronic equipment in the State of São Paulo. An evaluation of the behavior of these systems was carried out from 2012 to 2021, between the first and second phase of EPR implementation, considering the following variables: established goals, participating companies and results achieved, with two approaches: a) comparative analysis between the two engagement agreements established with entities in the electronics sector, signed, respectively, in the first and second phase; b) analysis of the aggregate results of the systems whose reverse logistics plans were presented to the state environmental agency in compliance with the regulation, between 2018 and 2021. Advances were noted from the first to the second phase, regarding the variety of waste covered, quantity and diversity of actors in the production cycle involved, significance of goals, geographic scope of waste collection points and quantities collected. From 2018 to 2021, the total number of collection points increased 37.4 times, and the amount collected almost quadrupled. The decisive factor for this advance was the publication of an innovative regulation between the two phases, binding the compliance with the EPR to environmental licensing at the state level.