The Observatory
Nobody knows what this costs. We're going to.
Every argument about EU packaging rules runs into the same wall: there is no public figure for what compliance actually costs a small seller. Trade bodies model it for large producers. Nobody measures the maker shipping forty kilos a year. The Observatory is the part of KontorBund that fixes that.
Why a number, and not a campaign
Because there is a provision to measure against. Art. 46(5) of
Regulation (EU) 2025/40 binds the producer responsibility organisations
themselves:
"Producer responsibility organisations shall ensure equal treatment of producers regardless of their origin or size, without placing a disproportionate burden on producers of small quantities of packaging, including packaging of packaged products, including small and medium-sized enterprises."
Art. 44(11)(d) adds that registration fees must be "cost-based and
proportionate". Art. 45(2) requires EPR costs to be set "in a
transparent, proportional, non-discriminatory and efficient way". And each
member state has to appoint someone to oversee how the schemes are carrying
this out.
"Disproportionate" is not defined. It is the kind of word that gets its meaning from evidence, and right now there is none — which means the schemes get to assume their pricing is fine. A median cost per €1,000 of revenue, collected from real sellers with the method published, is the evidence. That is the whole reason this page exists, and it is why one quote from you is worth more than another paragraph of argument from us.
Method
How the number gets built.
Four steps, in this order, every month. Members can see their own submission at any point and withdraw it at any point.
Collect
Members post real quotes — the country, the provider, the annual fee, what's included, and their rough packaging volume. Quotes from non-members are welcome too, and just as useful.
Strip
Shop name, member name and any identifying detail come off before anything is stored. What remains is a country, a price, a scope and a volume band.
Aggregate
We publish medians and ranges per country and per volume band, never individual rows. A band with fewer than five submissions isn't published at all — with four you can often guess who's who.
Publish
Openly, free, with the method attached and the sample size stated. Anyone may cite it. Anyone may challenge it, and we'd rather they did that than take it on trust.
Publications
What the Observatory puts out.
Nothing here is published yet — the association is weeks old and the dataset is still being gathered. These are the four things it will produce, listed honestly so you can see what you'd be contributing to.
The Cost of Compliance
A monthly figure: median compliance cost per €1,000 of revenue, split by country and by volume band. The number that's missing from every conversation about this file.
The Threshold Paper
The core argument, evidenced: a fixed administrative charge applied with no
volume threshold is regressive, and the effect is measurable. Framed as an
Art. 46(5) case — that the charge places a disproportionate
burden on producers of small quantities, which the schemes are legally
required not to do. Written to be handed to a rapporteur and to a scheme's
oversight body, not to be read by us.
Who Actually Left
A count of sellers who publicly stopped shipping to the EU, by home country and product category, with the reasons they gave in their own words. Departures are the clearest evidence of a threshold problem.
Consultation responses
Whenever the Commission or a member state opens a consultation touching packaging, product safety or small-seller thresholds, we answer it — and publish what we sent, in full, the day we send it.
Contribute
Send us one quote. That's the whole ask.
The dataset is the association's only real leverage — with enough rows we can tell any provider exactly what the market rate is and how many members we're bringing. Post yours in #quotes-and-costs on the Discord, in this shape:
Provider:
Annual fee, excl. VAT:
What's included: AR only / AR + registration / + PRO licence
Rough annual packaging volume:
Quote date: