EPR Costs in the EU: Fees by Country

Table of Contents

1. 1.How EU EPR Fee Systems Work
2. 2.Germany: Verpackungsgesetz (VerpackG)
3. 3.France: CITEO System
4. 4.Italy: CONAI System
5. 5.Spain: Ecoembes and Ecovidrio
6. 6.The Netherlands: Verpact
7. 7.Austria: ARA and Competing PROs
8. 8.Belgium: Fost Plus
9. 9.Sweden: FTI
10. 10.Ireland: Repak
11. 11.Czech Republic: EKO-KOM
12. 12.Finland: Rinki
13. 13.Multi-Market Total Cost
14. 14.PPWR Compliance Costs Beyond EPR Fees
15. 15.Strategies to Reduce EPR Costs
16. 16.Sources and Methodology
17. 17.How Packgine Helps

Extended Producer Responsibility fees vary dramatically across European Union member states. A packaging format that costs €50 per tonne in EPR fees in one country might cost €500 per tonne in another. Understanding these differences is critical for any company selling packaged products into the EU, and for making informed decisions about packaging design, material selection, and market strategy.

How EU EPR Fee Systems Work

Each EU member state operates its own EPR system for packaging, typically managed by one or more Producer Responsibility Organizations (PROs). While the underlying principle is the same, producers pay for the collection and recycling of their packaging, the implementation varies significantly in fee levels (how much per tonne), fee structures (flat rate vs. modulated), modulation criteria (what factors affect fees), and additional obligations (labeling, reporting, take-back).

The EU's PPWR is beginning to harmonize some aspects, but national implementation differences will persist for years to come.

Germany: Verpackungsgesetz (VerpackG)

Germany's packaging EPR system is the most established in Europe and one of the most complex. Producers must register with the Zentrale Stelle Verpackungsregister (ZSVR) and contract with a licensed dual system (PRO) for collection and recycling.

Germany does not publish a standard compliance fee table. Fees are quote-based across competing dual system PROs (Der Grüne Punkt, Interseroh+, Reclay, Zentek, Landbell, Noventiz, Veolia) and depend on material type, volume, contract terms, and recyclability profile. Indicative ranges from market sources suggest €80 to €400 per tonne depending on material, with plastics at the upper end. Always request quotes directly from dual system operators. (Source: Complydex PPWR Compliance Cost Guide, March 2026; PPWR Atlas, August 2026)

Fee Modulation: German fees are increasingly modulated based on recyclability. The Zentrale Stelle has published recyclability criteria that affect fee levels. Packaging designed for optimal recyclability can receive fee reductions of 10 to 30%, while poorly designed packaging (dark-colored PET, multi-layer films, non-separable components) pays higher rates.

Penalties: Operating without LUCID registration or with inaccurate reporting can result in fines up to €200,000. Distribution bans can be imposed on non-compliant products. Since 12 August 2026, Germany's Packaging Act (VerpackG) has been replaced by the Packaging Law Implementation Act (VerpackDG), which implements the PPWR at national level. The VerpackDG expands EPR obligations to B2B packaging that was previously exempt, while maintaining the LUCID register and dual system structure. Producers must still register with ZSVR via LUCID and contract with a licensed dual system, but the scope of obligated packaging has broadened. (Source: Tanso Blog, July 2026; PPWR Atlas, August 2026)

Total Cost for a Mid-Sized Company (€50M revenue, selling 500 tonnes of packaging annually into Germany): €75,000 to €200,000 per year in EPR fees (indicative, based on market intelligence, actual costs depend on negotiated dual system rates), plus €5,000 to €15,000 in registration, reporting, and audit costs.

France: CITEO System

France's EPR system, managed primarily by CITEO (formerly Eco-Emballages), is notable for its aggressive fee modulation based on eco-design criteria.

Fee Levels (2025 to 2026 confirmed CITEO schedule): Glass: €20 per tonne. Paper and cardboard: €258 per tonne. Plastics, rigid recyclable: €770 per tonne. Plastics, rigid hard-to-recycle: €1,400 per tonne. Aluminum: €243 per tonne. Beverage cartons: €468 per tonne. (Source: PPWR Atlas confirmed PRO rates, August 2026)

Eco-Modulation: France's eco-modulation system was enhanced on 1 January 2026 with new regulations expanding bonus and malus criteria. Bonuses of up to €1,000 per tonne are now available for recyclate derived from difficult-to-recycle waste streams, with a reduced rate of €550 per tonne applying during the 2026 to 2027 transition period. Malus surcharges of up to 100 percent continue to apply for carbon black pigments in plastics, non-separable multi-material packaging, and materials that disrupt sorting and recycling streams. Aluminum rates increased approximately 15 percent versus 2025, reaching €2.85 per kilogram. These malus fees can more than double the base EPR cost for poorly designed packaging. (Source: CITEO 2026 barème via Compliancr.io; Interzero EPR Expert France eco-modulation analysis, February 2026)

New in July 2026: France launched a separate professional and B2B packaging EPR stream with three approved eco-organisms: Citeo Pro, Léko Pro, and Twiice. B2B packaging rates are significantly lower than household rates, with plastics at approximately €218 per tonne and cardboard at approximately €34.7 per tonne. Companies with both consumer and B2B packaging now have two separate EPR obligations in France. The professional stream is sized at roughly €302 million for the first full year, rising toward €600 million per year by 2030. (Source: EPR Representative barème analysis, June 2026; Compliancr.io CITEO 2026 guide)

Total Cost for a Mid-Sized Company: €120,000 to €450,000 per year in EPR fees for a mid-sized company selling 500 tonnes of mixed packaging annually into France (highly dependent on packaging design, material choices, and recyclability profile).

Italy: CONAI System

Italy's packaging EPR system is managed by CONAI (Consorzio Nazionale Imballaggi) through material-specific consortia.

Fee Levels (2025 to 2026 confirmed CONAI CAC schedule): Glass (COREVE): €40 per tonne. Paper (COMIECO): €45 per tonne. Plastics (COREPLA): €87 to €790 per tonne, depending on sortability and recyclability classification. COREPLA classifies plastic packaging into sub-categories: easily sortable and recyclable packaging starts at €87 per tonne, while packaging that cannot be effectively sorted or recycled pays up to €790 per tonne. Aluminum (CIAL): €12 per tonne. Steel (RICREA): €10 per tonne. Wood (RILEGNO): €8 to €15 per tonne. (Source: PPWR Atlas confirmed PRO rates, August 2026; Complydex CONAI CAC range, March 2026)

Total Cost for a Mid-Sized Company: €40,000 to €180,000 per year.

Spain: Ecoembes and Ecovidrio

Spain's system splits packaging into two PROs: Ecoembes (lightweight packaging, plastic, metal, cartons) and Ecovidrio (glass packaging).

Fee Levels (2025 to 2026 confirmed Ecoembes schedule): Glass: €35 per tonne. Paper and cardboard: €115 per tonne. Plastics, rigid recyclable: €285 per tonne. Plastics, rigid hard-to-recycle: €748 per tonne. Aluminum: €40 per tonne. (Source: PPWR Atlas confirmed PRO rates, August 2026)

Important additional cost: Spain imposes a separate plastics tax (Impuesto sobre Envases de Plástico No Reutilizables) of €0.45 per kilogram on non-recycled plastic packaging, effective since January 2023. This tax applies on top of EPR fees and can significantly increase total compliance costs for companies using virgin plastic packaging. For example, 100 tonnes of virgin plastic packaging incurs €45,000 in plastics tax alone, before any EPR fees. Companies using packaging with 100 percent recycled plastic content are exempt from this tax. (Source: Spanish Tax Authority; Ecoembes compliance guide)

Total Cost for a Mid-Sized Company: €50,000 to €200,000 per year in EPR fees, plus up to €45,000 to €225,000 in additional plastics tax depending on virgin plastic usage.

The Netherlands: Verpact

The Netherlands operates a centralized system through Verpact (formerly Afvalfonds Verpakkingen).

Fee Levels (2025 to 2026 confirmed Verpact schedule): Glass: €100 per tonne. Paper and cardboard: €17 per tonne. Plastics: €1,220 per tonne (same rate applies to both recyclable and hard-to-recycle formats). Aluminum: €340 per tonne. Beverage cartons: €920 per tonne. (Source: PPWR Atlas confirmed PRO rates, August 2026)

The Netherlands has among the highest plastic and aluminum packaging EPR fees in Europe, reflecting the country's ambitious recycling targets, significant investment in advanced sorting infrastructure, and compact geography that makes collection logistics more efficient. The plastics rate of €1,220 per tonne is nearly double the next most expensive major market (France at €770 per tonne for recyclable plastics).

Total Cost for a Mid-Sized Company: €80,000 to €350,000 per year for a mid-sized company, with plastic-heavy packaging portfolios at the upper end due to the €1,220 per tonne rate.

Austria: ARA and Competing PROs

Austria operates its EPR system through the ARA (Altstoff Recycling Austria) and competing PROs.

Fee Levels (2025 to 2026 confirmed schedule): Paper and cardboard: €208 per tonne. Glass: €108 per tonne. Plastics, rigid recyclable: €1,040 per tonne. Plastics, rigid hard-to-recycle: €1,140 per tonne. Aluminum: €480 per tonne. Beverage cartons: €1,020 per tonne. (Source: PPWR Atlas confirmed PRO rates, August 2026)

Austria's fees are among the highest in Europe across most material categories. The €800 per tonne EU levy on non-recycled plastic packaging waste is already having a tangible impact on Austrian fee structures.

Total Cost for a Mid-Sized Company: €90,000 to €300,000 per year.

Belgium: Fost Plus

Belgium's EPR system is managed by Fost Plus for household packaging.

Fee Levels (2025 to 2026 confirmed Fost Plus Green Dot schedule): Paper and cardboard: €150 per tonne. Glass: €105 per tonne. Plastics, rigid recyclable: €360 per tonne. Plastics, rigid hard-to-recycle: €1,193 per tonne. Aluminum: €49 per tonne. Beverage cartons: €808 per tonne. (Source: PPWR Atlas confirmed PRO rates, August 2026)

Belgium has a notably wide spread between recyclable plastics (€360 per tonne) and hard-to-recycle plastics (€1,193 per tonne), creating a strong financial incentive to design for recyclability.

Total Cost for a Mid-Sized Company: €55,000 to €220,000 per year.

Sweden: FTI

Sweden operates through FTI (Förpacknings- och Tidningsinsamlingen) and has among the highest EPR fees in Europe across all material categories.

Fee Levels (2025 to 2026 confirmed schedule): Paper and cardboard: €612 per tonne. Glass: €257 per tonne. Plastics, rigid recyclable: €1,229 per tonne. Plastics, rigid hard-to-recycle: €1,795 per tonne. Aluminum: €1,155 per tonne. (Source: PPWR Atlas confirmed PRO rates, August 2026)

Sweden's fees are consistently the highest or second-highest in Europe, particularly for aluminum at €1,155 per tonne, more than four times the next most expensive major market.

Total Cost for a Mid-Sized Company: €120,000 to €400,000 per year.

Ireland: Repak

Ireland's EPR system is managed by Repak.

Fee Levels (2025 to 2026 confirmed schedule): Paper and cardboard: €46 per tonne. Glass: €23 per tonne. Plastics, rigid recyclable: €170 per tonne. Plastics, rigid hard-to-recycle: €620 per tonne. Aluminum: €9 per tonne. (Source: PPWR Atlas confirmed PRO rates, August 2026)

Ireland offers among the lowest EPR fees in Western Europe, particularly for aluminum at just €9 per tonne.

Total Cost for a Mid-Sized Company: €20,000 to €80,000 per year.

Czech Republic: EKO-KOM

The Czech Republic operates through EKO-KOM.

Fee Levels (2025 to 2026 confirmed schedule): Paper and cardboard: €283 per tonne. Glass: €73 per tonne. Plastics, rigid recyclable: €626 per tonne. Plastics, rigid hard-to-recycle: €675 per tonne. Aluminum: €206 per tonne. Beverage cartons: €434 per tonne. (Source: PPWR Atlas confirmed PRO rates, August 2026)

Total Cost for a Mid-Sized Company: €60,000 to €200,000 per year.

Finland: Rinki

Finland's EPR system is managed by Rinki.

Fee Levels (2025 to 2026 confirmed schedule): Paper and cardboard: €102 per tonne. Glass: €76 per tonne. Plastics, rigid recyclable: €238 per tonne. Plastics, rigid hard-to-recycle: €360 per tonne. Aluminum: €30 per tonne. Beverage cartons: €162 per tonne. (Source: PPWR Atlas confirmed PRO rates, August 2026)

Total Cost for a Mid-Sized Company: €30,000 to €120,000 per year.

Multi-Market Total Cost

For companies selling into multiple EU markets, the total EPR cost and compliance burden is multiplicative. A mid-sized company selling 500 tonnes of mixed packaging into all five major EU markets (Germany, France, Italy, Spain, Netherlands) can expect total annual EPR fees of approximately €350,000 to €1,400,000, plus compliance management costs of €30,000 to €100,000 per year, plus audit and reporting costs of €15,000 to €50,000 per year.

PPWR Compliance Costs Beyond EPR Fees

The PPWR (Regulation EU 2025/40), now in effect from 12 August 2026, introduces several compliance costs beyond traditional EPR fees that producers must budget for:

Declaration of Conformity (Article 17): Every packaging unit placed on the EU market now requires a Declaration of Conformity confirming compliance with substance limits, recyclability requirements, recycled content targets, labelling rules, and minimisation obligations. This is a new document requirement that did not exist under the previous Packaging Directive. Cost ranges from €500 to €2,000 per packaging type when prepared by compliance consultants, or approximately €10 per packaging type using automated compliance tools. For a company with 20 distinct packaging types, this represents a one-time cost of €200 to €40,000 depending on approach. The DoC must be updated whenever packaging materials or specifications change.

Laboratory Testing (Articles 13 and 14): The PPWR mandates testing for hazardous substances and restricted chemicals. Article 13 requires that concentrations of lead, cadmium, mercury, and hexavalent chromium must not exceed 100 parts per million combined. Article 14 bans per- and polyfluoroalkyl substances (PFAS) in food-contact packaging from 12 August 2026. Testing costs approximately €158 to €198 per sample for heavy metals analysis (ICP-OES method) and approximately €365 per sample for targeted PFAS analysis. For a typical company with 10 distinct packaging types, a full testing program covering heavy metals and PFAS costs approximately €1,580 to €5,630 as a one-time expense. Retesting is required only when materials or suppliers change. (Source: Measurlabs laboratory pricing benchmarks via Complydex, March 2026)

Authorized Representative (Article 42): Non-EU producers selling packaged products into the EU must appoint an Authorized Representative in each Member State where they need EPR registration. The AR acts as the legal point of contact for national authorities. Cost typically ranges from €1,500 to €5,000 per year for single-country representation, or €5,000 to €15,000 per year for multi-country bundles covering five or more markets. Some compliance service providers offer bundled AR plus EPR registration at approximately €1,000 per country per year. (Source: Complydex cost analysis, March 2026; EcoComply pricing)

Eco-Modulated Fee Timeline (Article 46): The PPWR mandates harmonized eco-modulation of EPR fees across all EU Member States based on packaging recyclability grades. The European Commission will adopt delegated acts establishing recyclability assessment criteria by 1 January 2028. Once published, eco-modulated fees are expected to take effect approximately 18 months later, around mid-2029. Under the grading system, packaging scoring Grade A (95 percent or more recyclable by weight) will pay the lowest fees. Grade B (80 percent or more) pays lower fees. Grade C (70 percent or more) pays standard fees. Packaging scoring below Grade C is banned from the EU market from 1 January 2030. From 1 January 2038, only Grades A and B remain permitted. The financial impact of this grading system will be substantial: companies with Grade A packaging could see fee reductions of 20 to 40 percent from base rates, while companies with Grade D or E packaging will face the highest fees before their packaging is banned entirely. (Source: PPWR Regulation EU 2025/40 Article 46 and Annex II Table 3; PPWR Atlas timeline; Freshfields Bruckhaus Deringer analysis, July 2026)

Simplified Reporting Threshold: Producers placing fewer than 10 tonnes per year of packaging on the market in a given Member State benefit from simplified reporting obligations under the PPWR. Registration and fee payment are still required, but the administrative burden is lighter. This threshold is particularly relevant for smaller e-commerce sellers who may sell across multiple EU countries without hitting 10 tonnes in any single one.

Packaging Labelling Requirements: Harmonized packaging labelling becomes mandatory from August 2028 (material composition labels) and February 2029 (reusability labels), or 24 months after the relevant implementing acts, whichever is later. This will require packaging redesign and reprinting across EU product lines.

Deposit Return Schemes: By 1 January 2029, Member States must implement deposit return systems for single-use plastic bottles and metal beverage containers up to 3 litres capacity. Exemptions apply for wine, spirits, milk products, and products consumed on HORECA premises. Member States already collecting over 90 percent by weight may apply for exemption.

Total PPWR Compliance Cost Estimate: For a mid-sized company selling into 5 EU markets with 20 packaging types, the total new PPWR compliance costs (beyond existing EPR fees) are approximately: Declaration of Conformity: €200 to €40,000 one-time. Laboratory testing: €3,160 to €11,260 one-time. Authorized Representative (if non-EU): €7,500 to €75,000 per year. Packaging redesign and relabelling: €10,000 to €100,000 one-time (highly variable). Total first-year PPWR-specific costs: €20,860 to €226,260 on top of annual EPR fees.

Strategies to Reduce EPR Costs

Companies can significantly reduce their EPR costs through several strategies. Material lightweighting reduces fees proportionally to weight reduction. Switching to mono-material designs can reduce fees by 20 to 50% in markets with eco-modulation. Increasing recycled content triggers bonuses in France and other markets with eco-modulation. Eliminating problematic elements such as carbon black, PVC, and non-separable components avoids malus surcharges. Centralized compliance management through a single platform reduces administrative costs by 30 to 50%.

Switch to mono-material designs to improve recyclability grades. Under the PPWR eco-modulation framework taking effect around mid-2029, packaging with Grade A recyclability (95 percent or more by weight) will pay the lowest EPR fees across all EU Member States. A switch from multi-layer laminates to mono-material alternatives can reduce fees by 30 to 60 percent in markets that already have eco-modulation, and will provide even greater savings once harmonized PPWR eco-modulation takes effect.

Prepare your Declaration of Conformity now. Even though enforcement is expected to ramp gradually, the legal obligation exists from 12 August 2026. Companies that prepare DoCs proactively avoid rush consultant fees and demonstrate compliance readiness during market surveillance inspections.

The most cost-effective approach is to design packaging that meets the highest recyclability standards (France's CITEO criteria or Germany's ZSVR standards), as this typically satisfies all other EU markets' requirements while minimizing fees across the board.

Sources and Methodology

Fee data from PPWR Atlas EU Packaging EPR Fee Tables (ppwratlas.com/fee-calculator), confirmed from each national PRO's published 2025 to 2026 schedule, last updated August 8, 2026. Supplementary verification from Complydex PPWR EPR Fees and Compliance Costs Guide (March 2026), Interzero EPR Expert France eco-modulation analysis (February 2026), EPR Representative France professional packaging barème analysis (June 2026), and CITEO 2026 tariff schedule via Compliancr.io. PPWR regulatory text: Regulation (EU) 2025/40, Official Journal of the European Union, January 22, 2025. All rates are base rates before eco-modulation and are reviewed annually by each PRO. Germany's fees are quote-based and indicative ranges are from market intelligence sources. Always confirm final rates with the relevant PRO before filing.

How Packgine Helps

Packgine gives you a single dashboard to manage EPR fees and compliance across all EU member states, eliminating the complexity of navigating country-by-country requirements manually.

EPR & PPWR Compliance Automation: Packgine tracks fee schedules, eco-modulation criteria, and filing deadlines for every EU market including Germany, France, Italy, Spain, the Netherlands, and beyond. Automated fee calculations ensure accurate reporting and avoid costly penalties.

Compliance Cost Estimating: Our cross-border cost modeling engine shows your total EPR exposure across all EU markets simultaneously. Compare current costs against optimized scenarios, see exactly how much you could save by redesigning specific packaging formats or switching materials in each country.

Alternative Product Suggestions: Packgine recommends packaging designs that minimize fees across all EU markets at once. Avoid France's malus surcharges, qualify for Germany's recyclability bonuses, and meet Italy's COREPLA requirements, all with a single, optimized packaging design. Each recommendation comes with country-by-country fee projections so you can quantify the savings.

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