EPR fees in the EU: who pays them, how they are set and what each country charges

Who pays an EPR fee: the producer, through a scheme or a representative

Each EU act puts the cost on the producer. A packaging producer has extended producer responsibility for the packaging it makes available for the first time in a country, and its contributions cover the waste-management costs the framework Directive lists plus the cost of labelling waste bins and of surveys of mixed municipal waste (Art. 45(1)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 45, paragraph 1Click opens the article on EUR-Lex., Art. 45(2)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 45, paragraph 2Click opens the article on EUR-Lex.). A battery producer pays for separate collection, transport and treatment, the same surveys, information to the public, and data gathering and reporting (Art. 56(4)Regulation (EU) 2023/1542, Batteries RegulationArticle 56, paragraph 4Click opens the article on EUR-Lex.). For electrical goods, each producer finances the waste from its own products, alone or through a collective scheme, and gives a guarantee when it places the product on the market (Art. 12(3)Directive 2012/19/EU, Waste Electrical and Electronic Equipment DirectiveArticle 12, paragraph 3Click opens the article on EUR-Lex.).

A seller outside the EU that makes the goods available for the first time directly to end users in an EU country is the producer there (Art. 3(15)(c)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 15, point (c)Click opens the article on EUR-Lex., Art. 3(15)(d)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 15, point (d)Click opens the article on EUR-Lex.). An authorised representative takes on your producer duties under a written mandate (Art. 3(20)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 20Click opens the article on EUR-Lex.). For batteries you need one in every country you sell to (Art. 56(3)Regulation (EU) 2023/1542, Batteries RegulationArticle 56, paragraph 3Click opens the article on EUR-Lex.). For packaging, PPWR Article 45(3)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 45, paragraph 3Click opens the article on EUR-Lex. makes one mandatory where you are established in another EU country and optional for a producer established outside the EU, but national law can require one: Germany and Spain do (Art. 45(3)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 45, paragraph 3Click opens the article on EUR-Lex.). The scheme’s price and the representative’s fee are two separate charges. In Germany the ZSVR says the representative takes on all your producer obligations except the LUCID registration, and that representatives charge fees for their services (ZSVR). No EU text and no ZSVR page gives a figure for that fee.

Two more places the cost can land:

• A marketplace. Where you sell through an online marketplace, you may give it a written mandate to meet the cost duties of PPWR Article 45(2)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 45, paragraph 2Click opens the article on EUR-Lex. on your behalf (Art. 45(4)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 45, paragraph 4Click opens the article on EUR-Lex.).
• The buyer. For electrical goods, an EU country may require producers to show purchasers the cost of collection, treatment and disposal when they sell, at no more than the best estimate of the actual cost (Art. 14(1)Directive 2012/19/EU, Waste Electrical and Electronic Equipment DirectiveArticle 14, paragraph 1Click opens the article on EUR-Lex.). France does: the household eco-contribution must appear on the invoice, in addition to the unit price, and in distance selling the buyer is told by any appropriate means (ecosystem, quoting article L541-10-20 of the Environment Code).

How a fee is set: per tonne, per kilogram or per unit, by material or by product type

The framework Directive sets the outline. A collective scheme publishes the contributions producers pay “per unit sold or per tonne of product placed on the market” (Art. 8a(3)(e)Directive 2008/98/EC on waste, as amended by Directive (EU) 2018/851Article 8a, paragraph 3, point (e)Click opens the article on EUR-Lex.). The contributions may not exceed the costs necessary to provide waste management in a cost-efficient way (Art. 8a(4)Directive 2008/98/EC on waste, as amended by Directive (EU) 2018/851Article 8a, paragraph 4Click opens the article on EUR-Lex.), and producers are treated equally regardless of origin or size, without a disproportionate burden on producers of small quantities (Art. 8a(1)(d)Directive 2008/98/EC on waste, as amended by Directive (EU) 2018/851Article 8a, paragraph 1, point (d)Click opens the article on EUR-Lex.). The register authority may charge a cost-based and proportionate fee for processing your registration, which is a different charge from the scheme’s price (Art. 44(11)(d)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 44, paragraph 11, point (d)Click opens the article on EUR-Lex., Art. 55(10)(b)Regulation (EU) 2023/1542, Batteries RegulationArticle 55, paragraph 10, point (b)Click opens the article on EUR-Lex.).

So a seller meets three kinds of charge:

Packaging tariffs weigh the packaging by material. Electrical-goods tariffs count units by type of equipment, and some add a modulation line for design. Battery tariffs weigh by chemistry, with light-transport batteries counted per unit. For small quantities, the schemes below publish a flat minimum (Citeo, and ecosystem for batteries) or a simplified scale (Citeo, and Ecologic for electrical goods).

PPWR eco-modulation has no start date: it follows two Commission acts, and it is in Article 6, not Article 45

Article 45Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 45Click opens the article on EUR-Lex. of the PPWR says what the packaging contributions cover. It does not modulate them. The modulation sits in Article 6Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 6Click opens the article on EUR-Lex.. Contributions “shall be modulated in accordance with the recyclability performance grades” 18 months from the entry into force of the delegated acts under Article 6(4)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 6, paragraph 4Click opens the article on EUR-Lex. and the implementing acts under Article 6(5)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 6, paragraph 5Click opens the article on EUR-Lex. (Art. 6(8)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 6, paragraph 8Click opens the article on EUR-Lex.). The Commission must adopt the delegated acts by 1 January 2028, including a framework for the modulation, and the implementing acts by 1 January 2030 (Art. 6(4)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 6, paragraph 4Click opens the article on EUR-Lex., Art. 6(5)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 6, paragraph 5Click opens the article on EUR-Lex.). The grades are A, B and C, for a recyclability score of at least 95%, 80% and 70% (Art. 6(3)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 6, paragraph 3Click opens the article on EUR-Lex., Annex II Table 3).

The Regulation names no calendar date. We read it this way: grade-based modulation applies 18 months after the acts under both paragraphs are in force, so if the Commission adopts the acts on its deadlines, it arrives around mid-to-late 2031, and earlier only if the Commission acts sooner. The Commission page for the PPWR, read on 5 October 2026, lists guidelines, an FAQ and a delegated decision on pallet wrappings, and none of these acts (European Commission).

The PPWR sets no amounts either: its recital says it harmonises the criteria “while not setting the actual amounts of such fees” (recital 35). Two other points matter before then:

• Recycled content. Contributions may be modulated by the share of recycled content in the packaging, taking into account the sustainability of the recycling technologies and the environmental costs; the paragraph sets no date and no methodology of its own (Art. 7(7)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 7, paragraph 7Click opens the article on EUR-Lex.).
• National modulation continues. Member States may use other criteria such as recycled content, re-usability or hazardous substances (recital 129), and the schemes below already do.

Other streams run on their own dates. Under collective fulfilment, producer responsibility organisations must modulate battery contributions at least by battery category and chemistry, and Chapter VIII of the Batteries Regulation has applied since 18 August 2025 (Art. 57(2)Regulation (EU) 2023/1542, Batteries RegulationArticle 57, paragraph 2Click opens the article on EUR-Lex., Art. 96(2)Regulation (EU) 2023/1542, Batteries RegulationArticle 96, paragraph 2Click opens the article on EUR-Lex.). The Commission may adopt an implementing act on the criteria, which does not fix the level of the contributions (Art. 57(7)Regulation (EU) 2023/1542, Batteries RegulationArticle 57, paragraph 7Click opens the article on EUR-Lex.). For textiles, the schemes must exist by 17 April 2028, and contributions are based on weight and modulated on ecodesign requirements (Art. 22a(14)Directive 2008/98/EC on waste, as amended by Directive (EU) 2025/1892 (textiles and footwear)Article 22a, paragraph 14Click opens the article on EUR-Lex., Art. 22c(5)Directive 2008/98/EC on waste, as amended by Directive (EU) 2025/1892 (textiles and footwear)Article 22c, paragraph 5Click opens the article on EUR-Lex.). The WEEE Directive sets no modulation criteria of its own; its schemes fall under the framework Directive’s rule that contributions under collective fulfilment are modulated, where possible, by durability, reparability, re-usability, recyclability and hazardous substances (Art. 8a(4)Directive 2008/98/EC on waste, as amended by Directive (EU) 2018/851Article 8a, paragraph 4Click opens the article on EUR-Lex.).

Germany publishes no packaging price list: registering costs nothing and each system sets its own price

For packaging, registration in LUCID, the German register, is free of charge (ZSVR). What you pay is the price of a “system”, the take-back scheme you must join. Packaging intended for shipment is always subject to system participation (ZSVR), so a seller shipping parcels to Germany pays a system.

The ZSVR lists ten system operators and says it may not recommend one or share information about prices (ZSVR). There is no official German price list. One operator, Lizenzero of the Interzero group, advertises a packaging licence from EUR 39 a year and says the cost depends on the quantity and the type of packaging material (Lizenzero). Its pages, read on 5 October 2026, give that starting price and a calculator, name no price per kilogram in their text and carry no year. The start pages of five other operators (Der Grüne Punkt, Landbell, Reclay, BellandVision and Noventiz) state no price.

Joining a system is a legal duty with a fine behind it. Not joining a system, or not in time, can cost up to EUR 200,000, and not registering up to EUR 100,000 (§ 66(1) no. 1 and 3, § 66(3) VerpackDG).

France: Citeo’s minimum is EUR 110, and the price follows the number of sales units

Citeo is one of the accredited household-packaging organisations in France. Its tariff for packaging placed on the market in 2026, updated on 22 June 2026, has three declarations, chosen by the number of consumer sales units (UVC) you place on the market in the year (Citeo):

• Under 10,000 units: a flat EUR 110 excluding VAT. It is also the minimum billing for any membership, and covers both the household-packaging and the graphic-paper declarations.
• 10,000 to 500,000 units: an optional simplified declaration. You count units by product family and Citeo applies a price per unit, with no technical data to give.
• Over 500,000 units: a declaration per unit, with the weight of each material priced per kilogram. Citeo says you get its eco-modulation bonuses, primes and malus by making this declaration per unit.

Citeo’s counting example treats the product’s own packaging as one unit and the shipping carton as another. A simplified family exists for “products with shipping parcel”, which the guide describes as suited to marketplaces and their sellers; the pages we read do not spell out whether its price includes the carton. A selection of its 2026 prices, in euros per unit:

The per-kilogram prices in the table at the top are from the same guide: for example 6.49 cents per kilogram of steel, 24.34 for aluminium, 25.81 for paper and cardboard, 2.01 for glass and 77.01 for polyethylene film. Paper and cardboard with more than 50% recycled fibres gets a 10% reduction.

The eco-modulation works on the total contribution of the unit. A bonus of 5% takes EUR 1,000 to EUR 950; a prime of EUR 100 takes it to EUR 900; a malus of 10% takes it to EUR 1,100. For 2026 Citeo raised five malus from 10% to 25% or 50% and removed five others.

Spain: Ecoembes prices household packaging per kilogram, and the 2027 list is public

Ecoembes publishes its prices for 2027 per kilogram, by material (Ecoembes). For household packaging:

• Paper and cardboard: EUR 0.117, or EUR 0.128 for packaging with plastic content under the single-use plastics rules.
• Steel: EUR 0.197. Aluminium: EUR 0.040. Glass: EUR 0.03761. Ceramic: EUR 0.011. Wood and cork: EUR 0.030.
• Plastic: PET drink bottles up to 3 litres EUR 0.278, PET trays and other rigid PET EUR 0.682, rigid HDPE EUR 0.282, other rigid plastics EUR 0.773, film and flexible packaging EUR 1.269.
• Drink and food cartons: EUR 0.544. Other materials: EUR 1.269.

For commercial packaging Ecoembes lists EUR 0.0025 per kilogram of every material where the final holder handles more than 85% of its commercial packaging waste through a private integral management, and EUR 0.020 to 0.173 per kilogram for other holders. It marks the commercial prices as indicative until the final 2027 ones are published.

Spain modulates too. Plastic and paper-and-cardboard prices move with eco-design criteria from a base price, and glass takes a 50% penalty over the base tariff where it has a ceramic closure, a glass composition other than soda-lime, or an associated element such as porcelain (Ecoembes). The price page states no minimum charge and does not say which category a shipping carton falls under. What Spain adds for packaging, with the representative route, the collective systems, the penalties and the 2026 declaration, is on Spain packaging EPR.

Italy: CONAI’s contribution is per tonne, by material and band, and imports pay it

CONAI, the Italian packaging consortium, charges a “contributo ambientale” per tonne by material. The page lists columns from 1 January 2026, 1 July 2026 and 1 October 2026; these are from 1 October 2026 (CONAI):

• Steel: EUR 5 per tonne. Aluminium: EUR 12. Glass: EUR 40. Wood: EUR 10. Aluminium capsules, pods and sachets for tea, coffee or other beverages: EUR 120 from 1 October 2026.
• Paper: EUR 45 for single-material paper and type A composites, rising by band to EUR 285 for type D composites.
• Plastic: nine bands, from EUR 51 per tonne for band A1.1 to EUR 922 for band C (40 and 790 until 30 September 2026).
• Compostable plastic: EUR 246 from 1 July 2026 (130 until 30 June 2026).

CONAI has modulated plastic since 1 January 2018 and paper and cardboard since 1 January 2019. The fee is invoiced on the first transfer within Italy, and the page says packaging and packaging material imported from abroad is subject to it because its use produces waste in Italy. The fee is a fee for additional services, so VAT is applicable. The page does not say how a seller outside Italy that ships packaged goods straight to Italian consumers pays it. For a foreign seller’s route, see Italy packaging EPR.

Read on conai.org, 5 October 2026.

Electrical goods: France prices per unit, Germany’s register charges its own small fee

France has two eco-organisations whose household scales we read. Both price by unit and type of equipment, and both modulate.

ecosystem, scale of 27 March 2026, applicable from 1 January 2026, in euros excluding VAT per unit (ecosystem): a smartphone with a separable battery EUR 2.44, where the scale shows a EUR 0.10 prime, and EUR 2.54 with a battery that is not separable. Its household scale carries a repairability or durability prime of EUR 8.33 or EUR 16.67 for equipment marked for it, and a prime for recycled plastic worked out on a base of EUR 450 per tonne, or EUR 550 per tonne where the plastic comes from recycled electrical waste.

Ecologic, simplified scale applicable from 1 January 2026, in euros excluding VAT per unit (Ecologic): a kettle EUR 0.38, a digital camera EUR 1.30, a handheld vacuum cleaner EUR 2.18, a robot vacuum cleaner EUR 4.76. The minimum annual billing is EUR 200. The simplified scale has no weights and no modulation and is reserved for small quantities; Ecologic may ask a member to move to the standard scale if the simplified declaration passes five tonnes. Where the use of an eco-modulation criterion is not justified, or in doubt, Ecologic applies the less favourable scale (Ecologic).

In Germany, stiftung ear charges the register’s own fees, not a take-back price. Its examples, net of VAT: registering in five types of equipment costs EUR 9.50 per type once, EUR 47.50 in total, and EUR 150.20 a year in quarterly and guarantee-check fees. For a representative acting for two companies, the register charges EUR 120.20 once and EUR 270.00 a year in the example (stiftung ear). That is the register’s fee, not the representative’s own price. The page says further fees can arise, for example by the quantity placed on the market or the guarantee form chosen. Its examples carry no year. For who registers, see WEEE registration.

Batteries: ecosystem prices per kilogram by chemistry, with a EUR 200 minimum per category

ecosystem’s battery scale, version of September 2026, applies from 1 January 2026, in euros excluding VAT (ecosystem). For portable batteries under 5 kg: alkaline EUR 0.374 per kilogram, lithium-ion with cobalt EUR 0.453, nickel-metal hydride EUR 0.175, lithium button cells EUR 2.60 and other button cells EUR 3.50. Batteries for light means of transport are priced per unit: lithium batteries under 2 kg EUR 1.50, rising to EUR 9.50 between 10 and 25 kg. The annual contribution per category cannot be less than EUR 200.

The register’s fee is separate. For batteries stiftung ear shows EUR 16.40 per type of battery once and EUR 3.80 a quarter, net of VAT, in its example (stiftung ear). The EU frame behind the tariff is in the Battery Regulation guide.

If you do not pay, the country sets the penalty

The PPWR leaves penalties to each EU country, due to be laid down by 12 February 2027 (Art. 68(1)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 68, paragraph 1Click opens the article on EUR-Lex.). We read the German amounts only: up to EUR 200,000 for not joining a system and up to EUR 100,000 for not registering (see the Germany section above). For France and Spain, see the packaging EPR guide: France fines up to EUR 7,500 per unit or tonne and up to EUR 30,000 more for not being registered, and in Spain not registering is a serious infringement (Ley 7/2022 Art. 108(3)(ac)), fined EUR 2,001 to 100,000 (Art. 109(1)(b)). Italy’s penalty provisions are in Italy packaging EPR.

What no source we read gives

• A German per-kilogram price. The ZSVR may not share prices, and the operator pages we read give a starting price, not a tariff. Meanwhile: the French, Spanish and Italian tables above show the range schemes publish.
• The authorised representative’s fee. The ZSVR says representatives charge fees and gives no amount. No EU text sets one.
• Italian and Spanish electrical-goods and battery tariffs. We read France and Germany for those streams only.
• A seller outside Italy and CONAI. CONAI says foreign companies are not obliged to join and may join voluntarily, and points platform sellers to art. 178-quater; a platform seller that does not use the platform’s services must join CONAI (CONAI). It does not say how that sits with the PPWR producer rule.
• A fixed date for PPWR eco-modulation. The Regulation gives none, only the 18 months after the Commission acts.

For the full set of EU duties that come with these fees, see PPWR.