KontorBund — Explainer
EPR and PPWR: who pays for the packagingLast checked 8 September 2026
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EPR and PPWR: who pays for the packaging
The short version
EPR makes whoever puts packaging on a market pay to collect and recycle it, and the fee itself is weight-based and genuinely small — a shop shipping 60 kg of cardboard into Italy owes about €2.70 of actual recycling contribution. What costs money is everything around it: registration, a scheme minimum, and an authorised representative, all of which are identical whether you ship 40 kg or 40 tonnes. National thresholds relieve the cheap half. Almost none of them touch the expensive one.
The idea, and why it is a reasonable one
Extended producer responsibility says that whoever puts packaging on a market should pay what it costs to collect and recycle it, rather than leaving that bill with the municipality. It is not a tax on selling and it is not, in principle, unfair. If your box ends up in a Belgian kerbside collection, somebody empties that bin, and the argument that it should be you rather than the resident of Ghent is a decent one.
Article 45(1) attaches the responsibility to the packaging you "make
available for the first time on the territory of a Member State". That phrase is doing all
the work, and it is why cross-border selling multiplies the problem: a parcel to Ghent is a
first making-available in Belgium, whatever your own country already charged you.
Your bill has two halves, and only one of them is the recycling
Every country in the set charges in the same two layers, whatever it calls them.
- The variable half — what you actually placed
- A rate per kilo per material. Paper, glass, steel, aluminium, plastic. This is the part that is genuinely about your packaging, and for a small shop it is almost nothing: a few kilos a year against tariffs measured in cents per kilo. This is EPR working as designed.
- The flat half — the cost of existing in that country
- Registration, scheme membership minimums, and the authorised representative. These are the same whether you ship 40 kg or 40 tonnes. This is the entire bill for a micro-seller, and it is unrelated to the environmental harm it is supposedly pricing.
Put concretely: Italy's CONAI charges paper and cardboard from about €45 a tonne. A shop shipping 60 kg of cardboard a year owes roughly €2.70 of actual recycling contribution. It also owes a joining fee, a registration, a declaration and — as a foreign seller — a representative. The €2.70 is the part everybody argues about and the part that does not matter.
What the flat half actually costs
Published minimums, from the country desks. These are floors, not bills: material rates sit on top, and the representative sits on top of that. Every figure links to the desk it came from, where it sits next to its source.
| Country | Scheme minimum or entry fee | Registration |
|---|---|---|
| Italy | €5.16 one-off CONAI participation fee | Included |
| Luxembourg | €50 a year, Valorlux | — |
| France | €80 flat, Citeo, under 10,000 units | Via the scheme |
| Belgium | €100 a year Fost Plus, €50 by direct debit | No annual fee before 2027 |
| Cyprus | €100 for the first tonne | Route not published |
| Poland | — | PLN 100 a year for a micro-enterprise |
| Czechia | CZK 1,600 EKO-KOM | Free |
| Austria | ~€129.50 ERP, €150 Interzero, flat-rate route | Via the representative |
| Sweden | PRO contract | SEK 1,250 a year, waived under 1 t |
| Germany | Dual system, competitive | Free — LUCID costs nothing |
The number nobody publishes
The authorised representative is the single largest line in a small cross-border seller's compliance bill, in most of the twenty-seven, and there is no published price for it anywhere. Not in Germany, where the register lists no providers at all. Not in France, where the mandataire duty is written into statute. Not in Austria, where you are not permitted to register without one.
We have looked, repeatedly. Providers quote privately, quotes vary by more than a factor of ten for the same service, and the market has the shape you would expect of one where the buyer is legally obliged to buy, cannot self-supply, and has no reference price.
Art. 44(11)(d) requires
registration fees to be "cost-based and proportionate"; Art. 45(2) requires the
costs to be established "in a transparent, proportional, non-discriminatory and efficient
way"; and Art. 46(5) requires producer responsibility organisations to act
without placing "a disproportionate burden on producers of small quantities of packaging".
Disproportionate to what? The Regulation does not say — so it takes its meaning from
evidence, and a median cost per €1,000 of revenue is that evidence. A collection of
anonymised quotes turns a complaint into an argument.
The reliefs, and what each one actually removes
Every country has a number that people repeat as though it were an exemption. Almost none of them are. It is worth being exact about what each relieves, because the answer is usually "the cheap part".
| The relief | What it actually removes | What survives |
|---|---|---|
| Netherlands, 50,000 kg | Genuinely everything on the Verpact side — no declaration, no contribution | The Art. 45(3) representative, which has no threshold. And single-use plastics and deposit containers are outside the threshold entirely |
| Poland, 1,000 kg | Specified recycling, product-fee and education duties, as de minimis aid | Registration, records and the annual report — and you must claim the relief in writing by 15 March every year |
| Czechia, 300 kg | The Czech national layer — and only if you also pass the second limb, a turnover test | Everything the PPWR imposes. A national relief cannot disapply an EU regulation |
| Slovakia, 100 kg | The Slovak representative duty in § 27(4)(b), under § 54(6). Real law, not a myth | The EU representative under Art. 45(3), plus registration, records and the 28 February report |
| Denmark, 8 t | The category breakdown — you may report one total figure instead | Everything else |
| Spain, 15 t | A shorter form | Everything else |
| Sweden, 1 t | A SEK 1,250 enforcement fee | Everything else. Responsibility applies regardless of quantity |
| Malta, 100 kg | A simplified declaration form | It is expressly not described as an exemption |
Art. 44 registration and
Art. 45(3) representation have no threshold anywhere in the Union. So
the relief always removes some of the variable half — the cheap part — and never touches
the flat half, which is the part that closes shops. The Netherlands is the one real
exception, and even there the representative survives.
One relief that is real, and underused
Article 44(8): a producer that made available less than 10 tonnes in
a calendar year reports a reduced data set — Annex IX, Part B, point 2, rather than the
full schedule. It is an EU-level provision, it does not depend on any national option, and
everyone reading this page is under it.
It will not save you money directly. What it saves is the hours, and the hours are a real cost for a one-person business: the difference between a full material-by-material breakdown and the short form is an afternoon per country per year. Ask your scheme for the reduced set by name and by article — several will simply send the full form otherwise, because most of their members are not you.
Sources
The article numbers were read in the Regulation. Every money figure comes from the country desk linked beside it, where it sits next to the national source it was taken from — so if one is stale, it is stale in one place and you can see when it was checked.
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Regulation (EU) 2025/40 (PPWR) — EUR-Lex Source for
Art. 45(1)(responsibility attaches to first making available on a member state's territory),45(2)(costs established transparently, proportionally, non-discriminatorily),44(8)(the under-10-tonne reduced reporting set),44(11)(d)(cost-based and proportionate fees) and46(5)(no disproportionate burden on producers of small quantities). Read directly for this page -
The twenty-seven country desks Every fee, threshold and relief above is linked to the desk it came from. Each desk carries its own national sources and the date it was last checked
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The KontorBund Observatory Where the missing number goes once enough people contribute it — the anonymised cost dataset, and the reason
Art. 46(5)is worth having evidence for
Help us finish this page
The gap in this page is a single number: what an authorised representative costs, per country. It is the largest line in most small sellers' compliance bills and there is no published price for it in any of the twenty-seven. If you have been quoted — whether you accepted it or ran away — that figure is the most useful thing you own. Quotes go into the Observatory anonymised, and nothing identifying is published.