This paper analyzes Extended Producer Responsibility (EPR) today, twenty years since the emergence of the concept. The paper concentrates on the question of how the (improper) allocation of responsibilities amongst the producers may impact the core aspect of EPR: the creation of design incentives. The analysis takes the prominent area of electrical and electronic equipment (EEE) as a case study. The narrative in the paper proceeds on four fronts. First, it attempts to clarify certain key concepts relating to EPR, because they have evolved and sometimes become blurred during the practical implementation of EPR. Second, the paper will discuss issues, which today appear to constitute the most prominent challenges in creating product design incentives through EPR from the perspective of division of responsibilities. These challenges should be at the top of the policy debate and agenda. Third, the paper makes use of more than ten years of practical experience that has accumulated in EPR policies in the European Union (EU), the U.S. and Japan by highlighting practical examples of approaches and solutions to creating design incentives through a proper division of responsibilities . Fourth, the analysis uses multi-level governance to develop a systemic framework of analysis for EPR. More generally speaking the paper serves as a case for portraying the challenges that face second generation environmental law and policy tools in greening the global economy.