EU Packaging EPR Costs: What Can You Owe Even If You Make No Sales?
Packaging EPR is not one EU tax and it does not have one EU price. Some costs follow kilograms sold. Others arise simply because a Producer remains registered, belongs to a compliance scheme or keeps an authorised representative.
Direct answer
If you place no packaging on a market, your variable weight-based contribution may fall to zero. Fixed, minimum, registration, representation or supervision charges can still remain.
PPWR does not establish one harmonised EU fee schedule. Article 45 and the Waste Framework Directive place financing responsibility on Producers, while the actual national systems, PRO tariffs, minimum contributions, administrative fees, levies and deposit mechanisms differ by Member State.
This is why the question “How much is EPR in Europe?” has no useful single-number answer. A business selling the same carton, pouch or bottle into ten EU countries can encounter ten different billing structures.
The first distinction is between money calculated from packaging volume and money that exists independently of packaging volume. That distinction becomes particularly important when a business registers in a market but subsequently sells nothing there.
Four cost layers
Do not put every payment into one box called “EPR fee”.
Registration, supervision or administration fees payable to a statutory authority or register.
Waste-management contributions normally based on material, weight, packaging type or units.
Private EPR AR or local representation charges where an appointment is legally or operationally required.
Separate environmental taxes, litter charges, SUP contributions and deposit-return cash flows.
Usually disappears if the relevant quantity is genuinely zero.
Can remain payable even when the calculated weight-based fee is lower.
May continue until the registration, contract or mandate is formally closed.
EU27 current cost map · 30 August 2026
What packaging EPR currently costs across all 27 Member States.
| Country | Public / fixed cost | Current PRO / system cost anchor | If market quantity is zero |
|---|---|---|---|
| Austria | ARA applies a minimum compliance fee. Its published example confirms a €90 minimum, plus applicable VAT. | 2026 ARA tariffs are material-specific and separated between household and commercial packaging. Small quantities up to 1,500 kg can use a flat-rate arrangement. | An active ARA relationship can still produce the minimum charge even where the calculated material fee is below it. minimum fee |
| Belgium | Fost Plus household-packaging minimum: €100; €50 reduction where direct debit conditions apply. | 2026: glass €0.1052/kg; paper-cardboard €0.1503/kg; clear colourless PET bottle €0.3604/kg; PP film €2.2095/kg. Separate 2026 litter levy can also apply. | Fost Plus minimum can remain payable. Reusable-only declarations also pay the minimum. minimum fee |
| Bulgaria | ECOPACK minimum annual fee: €80 excluding VAT. | 2026 base rates: steel €0.066/kg; paper €0.118/kg; plastic €0.125/kg; glass €0.144/kg; aluminium €0.152/kg; other €0.205/kg. | Minimum contractual fee remains relevant even at very low volume. minimum fee |
| Croatia | Packaging-waste management fees are paid into the Environmental Protection and Energy Efficiency Fund system; beverage packaging can also carry a separate deposit. | Current charges depend on the Fund's applicable packaging category and schedule. There is no single universal 2026 €/kg packaging rate suitable for all packaging. | Quantity-based management liability can fall with zero placement, but reporting/account status must still be checked. statutory schedule |
| Cyprus | Green Dot Cyprus operates the collective packaging system. | The public fee page reviewed on 30 August 2026 still labels its numeric tariff table “2017–2025”. A 2026 declaration process exists, but a new public 2026 tariff was not confirmed from the available primary tariff page. | Do not assume the older €100 small-volume table is the current 2026 price without confirmation. verify current tariff |
| Czechia | EKO-KOM annual fee: CZK 1,600 + VAT. | Separate 2026 material price list applies to collective compliance. EKO-KOM also publishes its remuneration/payment mechanics. | The annual fee is distinct from material remuneration. fixed annual |
| Denmark | DPA one-off registration: DKK 1,000. Annual minimum: DKK 250. | DPA packaging administration rate currently published at DKK 74.67/tonne in its fee schedule. Danish EPA supervision charge for 2026: DKK 0.018/kg. Collective-scheme waste-management charges are additional. | The DPA minimum means registered status can still carry cost at very low or zero volume. registration + minimum |
| Estonia | PRO tariff rather than one national flat registration price. | Eesti Pakendiringlus 2026: glass €86/t; mono plastic €255/t; composite plastic €320/t; paper €85/t. ETO publishes comparable 2026 tariffs. VAT is additional. | Contract terms determine any minimum or account fee. operator-specific |
| Finland | Producer organisation charges include a one-off registration fee and annual business service fee in addition to recycling fees. | 2026 light-declaration consumer packaging: paper €0.102/kg; plastic €0.238/kg; metal €0.030/kg; glass €0.076/kg; wood €0.0021/kg, VAT 0% before VAT is added. | Zero recycling volume does not automatically remove fixed/service components. multi-part fee |
| France | There is no volume threshold that removes household-packaging REP status merely because the Producer is small. | Citeo, Adelphe and Leko publish 2026 household-packaging contribution structures. Contribution depends on declaration method, units, material and eco-modulation. Professional packaging has its own 2026/2027 architecture. | A zero declaration can eliminate variable units, but membership/IDU and other continuing obligations must be checked before assuming zero cost. PRO-specific |
| Germany | LUCID registration and data reporting: €0. | System participation is a private contract with an approved system operator. Price depends principally on material and volume; ZSVR does not publish or recommend commercial rates. | No LUCID fee. A private system contract may nevertheless contain commercial minimums or other contractual terms. register free |
| Greece | HERRCO's current 2026 structure includes a minimum/base contribution reported at €500 annually and a joining mechanism linked to prior-year contribution. | 2026 tariff is material + packaging-unit based; published examples include €0.0004 per packaging unit and material-specific €/tonne contributions. | Fixed/minimum components can remain even when market volume is small. minimum + variable |
| Hungary | Statutory EPR tariff administered through the MOHU framework. | 2026 packaging rates: plastic HUF 219/kg; paper/cardboard 173; metal 186; glass 107; wood 22; composite 191; textile 148; other 129. | Quantity-based EPR fee can be zero where no relevant packaging is placed on market, subject to reporting/account obligations. statutory tariff |
| Ireland | Repak fee structure depends on supply-chain role and material. | 2026 Brandholder/Importer component: paper/cardboard €41.60/t; glass €19.14/t; rigid/flexible plastic €165.70/t; non-recycled plastic €616.22/t. | Variable material charge depends on packaging handled; membership and any joining/back-fee position must be checked separately. role-based tariff |
| Italy | CONAI Environmental Contribution is subject to VAT. | Current 2026 examples: steel €5/t; aluminium €12/t; paper from €45/t; glass €40/t; plastic bands range from €40/t up to €790/t before the 1 October 2026 changes. | Material contribution follows quantities, but consortium/account obligations must be reviewed separately. material tariff |
| Latvia | Below 300 kg/year, participation in a PRO is not mandatory, but Natural Resources Tax remains relevant. At 300 kg or more, packaging management via PRO or individual system is required under the current framework. | Latvijas Zaļais punkts 2026, excl. VAT: glass €0.124/kg; paper/cardboard €0.057/kg; wood €0.042/kg; steel €0.097/kg; aluminium €0.109/kg; beverage composite €0.375/kg. | Zero volume can eliminate weight-based liability, but the tax/PRO status should be formally reconciled. PRO or tax |
| Lithuania | Current national framework also includes environmental pollution tax exposure where applicable. | Gamtos Ateitis 2026, excl. VAT: glass €190/t; paper €289/t; recyclable plastic €540/t managed; PET €790/t; composite €952/t; non-recyclable categories €992/t. | Current law exempts Producers placing no more than 0.5 t/year from the packaging-pollution tax, while other registration/accounting duties can remain. threshold + tariff |
| Luxembourg | Packaging compliance is generally fulfilled through Valorlux or another legally available route. | No single statutory national €/kg tariff exists. A current 2026 public tariff figure suitable for universal application was not confirmed in the primary sources reviewed; the applicable Valorlux tariff/contract must be used. | Contract and membership conditions determine any continuing minimum charge. operator tariff |
| Malta | Current collective schemes use annual minimum compliance charges. | 2026 published scheme data indicate a €200 minimum, excluding ERA registration fees and VAT. Representative sales-packaging rates are approximately €147–€207/t for common materials depending on scheme/material. | The minimum can remain payable despite very small volumes. minimum fee |
| Netherlands | Verpact applies the Packaging Waste Management Fee; different packaging categories have different tariffs. | 2026: glass €0.100/kg; paper/cardboard €0.017/kg; rigid plastic €1.220/kg; flexible plastic €1.320/kg; aluminium €0.340/kg; beverage cartons €0.920/kg. | Variable liability follows declared packaging; reusable packaging has a €0.015/kg system-rate component. public tariff |
| Poland | No single national PRO €/kg tariff is charged to every Producer. Commercial recovery-organisation contracts are market-based. | Statutory product fee is principally a shortfall mechanism. Examples include PLN 1.40/kg for aluminium and PLN 0.30/kg for glass on the statutory shortfall. Separate DRS failure charges can also arise. | Zero packaging means no quantity shortfall, but contractual recovery-organisation costs may still exist. shortfall + contract |
| Portugal | SIGRE contribution depends on chosen management entity, material and urban/non-urban flow. | Sociedade Ponto Verde 2026 non-urban base: glass €0.0065/kg; paper/cardboard €0.0077/kg; plastics €0.0051/kg; aluminium €0.0040/kg; VAT additional. | Variable contribution follows declared quantity; contractual/account status should still be closed formally. flow-specific |
| Romania | Environmental Fund legislation imposes a statutory RON 2/kg contribution for specified packaging-recovery shortfalls. | Ordinary collective compliance is generally contracted with an authorised OIREP. OIREP commercial tariffs are operator-specific rather than one national public tariff. | No quantity normally means no recovery shortfall, but OIREP contract/minimum conditions can remain. shortfall + OIREP |
| Slovakia | Collective compliance is provided through authorised PROs. | ENVI-PAK 2026: glass €0.109938/kg; standard plastic €0.337751/kg; paper/cardboard €0.109968/kg; aluminium €0.139991/kg; beverage carton €0.319788/kg. | Variable contribution follows quantities; contract conditions determine fixed exposure. public PRO tariff |
| Slovenia | Multiple authorised packaging-waste management companies operate. | No single national tariff applies. Current government decisions allocate packaging-waste shares among Dinos, Embakom, Surovina, Interzero, Recikel, Slopak and others. A public 2026 universal Slopak tariff was not confirmed. | Cost is contract/provider-specific. quote / contract |
| Spain | RPP is the national producer-register layer; EPR fulfilment then operates through authorised individual or collective SRAP/SCRAP structures. | There is no single national €/kg packaging contribution. Ecoembes and other authorised systems apply their own packaging/category tariff structures. | A zero declaration may remove variable PRO quantities, but registration and representation status can remain active. SCRAP-specific |
| Sweden | NPA annual fee: SEK 2,500 excluding VAT. Swedish EPA annual supervision fee: SEK 1,250 per Producer. | Material-specific packaging charges are added to the NPA annual fee and finance municipal collection, logistics and recycling. | Fixed annual and supervision fees make Sweden a clear example where active registration can cost money despite negligible packaging volume. two fixed fees |
In competitive or multi-PRO markets, the legally relevant price may exist in a private contract rather than a statute. Conversely, a statutory rate may be a penalty or shortfall contribution rather than the normal cost of compliant participation. The two should never be compared as though they were the same fee.
The zero-sales test
“We sold nothing this year” should trigger five questions, not one.
First, was the company actually a Producer during the period? A business that ceased all relevant first-making-available activity may have no packaging quantity to report, but its registration can remain open until properly amended or cancelled.
Second, does the national system impose a minimum annual contribution? Belgium, Austria, Bulgaria and several collective schemes provide clear examples of this mechanism.
Third, is there an independent registration or supervision charge? Denmark and Sweden demonstrate why this must be kept separate from the recycling contribution.
Fourth, is an EPR Authorised Representative still appointed? Representation is a private professional service and can continue to cost money even where the underlying annual packaging declaration contains zero kilograms.
Fifth, has the Producer formally terminated the PRO, system or representation contract? A zero declaration is not necessarily a cancellation notice.
Public registration can cost €0.
LUCID registration and reporting are free. The recycling cost comes from the private system-participation contract. This makes the public fee and commercial system fee easy to distinguish.
Zero kilograms can still leave fixed costs.
NPA publishes an annual SEK 2,500 fee and the Swedish EPA separately charges SEK 1,250 annually for supervision. Weight-based packaging fees sit on top.
Calculate EPR cost country by country, then separate fixed money from variable money.
The safest EU cost model has separate lines for authority and registration charges, PRO or system contributions, EPR representation, taxes and levies, deposits, VAT and private professional services. A zero-sales year can reduce a weight-based contribution to zero while leaving one or more of the other lines untouched.
Frequently asked questions
Four answers worth knowing before budgeting.
Do I pay packaging EPR if I make no sales?
Variable weight- or unit-based contributions may be zero if no relevant packaging is placed on the market. Minimum annual fees, registration charges, supervision fees, representation charges or contractual costs may still remain.
Is there one EU packaging EPR fee per kilogram?
No. PPWR does not create a single EU tariff. Member States and authorised systems use different material classifications, minimum charges, eco-modulation models, taxes and administrative fees.
Is an EPR fee the same as an EPR Authorised Representative fee?
No. A PRO or system contribution finances packaging-waste obligations. An EPR AR fee is a private professional charge for representation and administration.
Why do some countries show no public EPR tariff?
Some markets use competing private compliance organisations whose prices are contractual. Others publish only statutory shortfall or penalty rates. Absence of one national tariff does not mean that compliance is free.
References