EU Compliance · Packaging EPR
EU Packaging EPR Fees Calculator
Estimate published base contributions for supported packaging in Spain and Italy. Check the calculation basis and excluded materials before using the subtotal.
Tariffs last verified 2026-09-10 or later
EPR fee breakdown estimator
material × weight × country| Country / material | Basis | subtotal | ||
|---|---|---|---|---|
| ES | ||||
| Paper & Board (non-SUP, no plastic) | base contribution; sources below | €115.00 | ||
| ES subtotal | €115.00 | |||
This subtotal includes only supported rows. Missing materials and markets, scheme adjustments and other charges are excluded; it is not a complete invoice.
Selected Spanish Ecoembes and Italian CONAI base rates are calculated as annual weight times the applicable material rate. Plastic and composite packaging need classifications this form does not collect. Spanish glass needs both kilograms and unit counts. France needs the applicable declaration method; Germany needs a dual-system quote. Neither receives an invented weight proxy.
Source tables: Ecoembes 2025, Ecoembes 2026, CONAI 2026, CONAI July 2025 changes. Active calculator rows verified 2026-09-10–2026-09-10. Verification of these rows does not certify every rule in the registration guides.
- LUCID / ZSVR
- Citeo
- CONAI
- Ecoembes
Estimator, not legal advice
Results include supported base contributions only, not a complete invoice. Other charges, adjustments and missing classifications are excluded. LUCID is a register, not a tariff provider. Check the applicable scheme and declaration method before filing.
Packaging EPR registration and fees, country by country (2026)
There is no EU-wide packaging EPR registration. Even after the PPWR (EU) 2025/40 starts applying on 12 August 2026, producer registers stay national — the regulation obliges every member state to run one, not to merge them. In practice you register in each country where you are the first to place packaged goods on the market. Here is how the eight markets most cross-border sellers hit actually work:
| Market | Where you register | What you pay (2026) | Marketplace check |
|---|---|---|---|
| Germany | LUCID register (ZSVR) — free — then license with a dual system | Supplier-specific dual-system contract; request a current quote | Amazon hard-blocks listings without a LUCID number |
| France | Eco-organisation (Citeo, Adelphe or Léko) → ADEME unique identifier (IDU) | Hybrid per-unit (CSU) + per-kg tariff; €80 flat rate under 10,000 units/yr | Marketplaces must collect your IDU or pay in your place |
| Spain | Registro de Productores de Producto (packaging section, MITECO), via your SCRAP | Punto Verde €/kg per material; 2026 tariffs apply from 1 January 2026 | Non-established sellers must appoint a Spanish authorised representative |
| Italy | CONAI membership + periodic declarations | CAC per tonne and packaging class; 2026 changes depend on material and date. Import forfait is a separate declaration basis. | — |
| Netherlands | Verpact (formerly Afvalfonds Verpakkingen) | Waste-management fee only above 50,000 kg/yr; no threshold for single-use-plastic items | — |
| Belgium | Fost Plus (household) / Valipac (industrial & commercial) | Per material, from the first gram; annual declaration due 28 February | Amazon.be and bol check Fost Plus membership |
| Austria | An approved system (ARA a.o.); foreign distance sellers need an authorised representative since 2023 | System tariff per material × kg | Platforms must verify sellers’ EPR compliance since 1 January 2023 |
| Poland | BDO register — the BDO number is your EPR number | Per-material rates plus product fee if targets are missed | Allegro has been tightening EPR checks since August 2025 |
Sources: ZSVR/LUCID, Citeo rate guide, Ecoembes, Verpact rates, Fost Plus, ARA. Registration guidance is separate from the calculator rate verification; check current scheme requirements before filing.
How to register: Germany, France and Spain step by step
Germany — LUCID plus a dual system (VerpackG)
- Create your producer account in the LUCID packaging register at the ZSVR. Registration is free, fully digital, must be done in your own company name (it cannot be delegated to an agency), and lists every brand you sell into Germany.
- Sign a participation contract with one of the ~10 competing dual systems (Interseroh+, Der Grüne Punkt, Landbell…). This licence fee — priced per material × weight — is your real annual cost; there is no single official tariff.
- Enter your chosen system and planned volumes back into LUCID. Registration without system participation is still non-compliance.
- Report the same volumes to both LUCID and the dual system, and keep the two in sync. Fines run up to €100,000 for a missing registration and up to €200,000 for missing system participation, plus a distribution ban.
Full walk-through: LUCID packaging registration in Germany — the register, the dual-system licence and the volume reports, step by step.
France — Citeo, the ADEME identifier and the Triman
- Join an approved eco-organisation for household packaging — Citeo (or Adelphe / Léko).
- You are then issued a unique identifier (IDU) by ADEME, France’s ecological-transition agency — the number marketplaces ask for as proof you contribute.
- Declare by the end of February for the previous year. Under 10,000 consumer sales units/yr you can pay a flat €80 contribution; up to 500,000 units there is a simplified declaration that folds the shipping box into 64 product-family rates.
- Label household packaging with the Triman logo and Info-tri sorting instructions — a labelling duty that exists on top of the fee.
Full walk-through: Citeo packaging EPR registration in France — the eco-organisation, the ADEME unique identifier and the declaration calendar.
Spain — the producers’ register and your SCRAP (RD 1055/2022)
- Not established in Spain? Appoint an authorised representative there first — Royal Decree 1055/2022 makes this mandatory for foreign producers, including marketplace sellers.
- Register in the Registro de Productores de Producto (packaging section) run by the ministry (MITECO); in practice your SCRAP files this for you and you receive a Spanish packaging-register number.
- Contract a collective scheme — Ecoembes for household packaging — and pay the Punto Verde tariff per material × kg (2026 tariffs approved to apply from 1 January 2026).
- File the annual packaging declaration. Data or registration failures are sanctionable, with fines that start above €10,000 for serious infringements under Spain’s waste law.
Full walk-through: Spain packaging EPR (RAP) registration. Registering somewhere else? There are step-by-step guides for Hungary (MOHU) and for WEEE registration across the EU, country by country — electricals are a separate register from packaging in every member state.
Marketplace enforcement: the LUCID number on Amazon, and what came after
Germany turned packaging EPR from a paper duty into a listing blocker. Since 1 July 2022 German law obliges marketplaces to verify that sellers are registered, and Amazon began blocking non-compliant offers on Amazon.de from mid-June 2022: no valid LUCID number in Seller Central, no active listings. Plan lead time — a fresh registration plus a dual-system contract can take weeks end-to-end, and Amazon’s own validation of a submitted LUCID number takes around five working days.
France runs the other enforcement model: marketplaces must collect your ADEME unique identifier, and where a seller cannot show one the platform itself becomes liable for the eco-contribution — which is why Amazon requests IDUs for packaging (and for the other French EPR streams such as textiles and furniture). Austria copied the verification duty from 1 January 2023, obliging platforms to contractually ensure their sellers comply, and in Poland Allegro has been restricting sellers who cannot show a BDO number since August 2025. The direction of travel is uniform: the marketplace is becoming the enforcement point, so an unregistered market is increasingly an unsellable market.
Common packaging EPR mistakes cross-border sellers make
- Registering only at home. EPR follows the destination market, not your company seat. Selling from Spain into Germany and France means Spanish, German and French obligations in parallel.
- Treating the LUCID number as the whole job. In Germany registration and dual-system participation are two separate legal duties — each with its own fine. A LUCID number without a licence contract (or vice versa) is still non-compliance.
- Forgetting the shipping box. The carton, filler and tape you add to fulfil an order are packaging you placed on the market. For direct-to-consumer parcels the seller is typically the obligated producer of that shipment packaging.
- Renting someone else’s number. German registration is personal and non-transferable; a “shared” LUCID number offered by an intermediary does not cover you and marketplaces cross-check the registered company name.
- Missing the declaration windows. Most schemes settle annually early in the year — Fost Plus and Citeo declarations for the previous year are due by 28 February. Late filings trigger estimates, surcharges or suspension.
- Assuming a small-seller exemption exists everywhere. Thresholds are national: the Netherlands only charges the fee above 50,000 kg/yr, France offers the €80 flat rate — but Germany and Belgium obligate you from the first item and the first gram, with no de-minimis.
EU packaging EPR fees — frequently asked questions
What is packaging EPR and who has to pay it?
Extended Producer Responsibility (EPR) makes the company that first places packaged goods on a national market financially responsible for collecting and recycling that packaging. If you sell physical products into an EU country — including cross-border e-commerce — you are usually the obligated producer there and must register with that country’s Producer Responsibility Organisation (PRO) and pay an annual fee.
Why is there no French fee estimate?
This calculator does not produce a French amount. Citeo has declaration methods requiring unit counts and packaging details that kilograms alone cannot establish. Select the applicable method in the Citeo rate guide.
How is Italy’s CONAI plastic contribution calculated?
CONAI plastic contributions depend on packaging classes and effective dates. The import forfait applies to a separate simplified declaration basis across packaging materials; it is not a generic plastic rate. Plastic is excluded here until its classification and period can be supported. For 2025 wood and glass, the estimate explicitly assumes half the annual kilograms in each half-year.
Why is there no German fee estimate?
Germany requires a dual-system quote. We have no retained, verified quote sample to support a numerical range, so Germany is excluded from the subtotal. LUCID is the packaging register, not a supplier tariff table.
How accurate are these estimates?
The amount is a subtotal of supported base contributions, not an invoice. Each active row cites its source, rate, effective period and verification date. Spanish commercial rates assume other final holders, excluding comprehensive-management agreements and hazardous-waste surcharges. Recycling bonuses are not applied automatically. Missing classifications, unit counts, taxes and other charges must be resolved separately.
Does the PPWR change my EPR fees?
The Packaging and Packaging Waste Regulation (EU) 2025/40 (PPWR) applies from 12 August 2026 and will harmonise eco-modulation and registration rules across the EU, but EPR fees stay set per-country by each national PRO. The applicable rates remain country-specific; the PPWR mainly tightens design and modulation criteria over time.
Do I need EPR registration in every EU country I sell to?
Yes — in every country where you are the first to place packaged goods on the market, which for a cross-border e-commerce seller usually means every country you ship consumer orders to. There is no EU-wide registration number: Germany wants a LUCID number, France an ADEME identifier, Spain an entry in its producers’ register, Poland a BDO number, and so on. The PPWR keeps registers national even after August 2026, so “registered in one member state” never covers the others.
What is a LUCID number and why does Amazon ask for it?
The LUCID number is your registration ID in Germany’s public packaging register, run by the ZSVR. German law obliges marketplaces to verify it, so Amazon requires a valid LUCID number in Seller Central for anyone selling on Amazon.de and has blocked non-compliant listings since July 2022. The number must be registered to your own company name — Amazon validates the match, typically within about five working days of submission — and it only makes you compliant together with an active dual-system licence.
Does my shipping box count as packaging I have to pay for?
Usually yes. The shipment carton, void fill and tape you add to deliver an order are “service packaging” you placed on the destination market, and for direct-to-consumer parcels the seller is normally the obligated producer of that packaging. France even prices it explicitly: Citeo’s simplified declaration folds the shipping box into its 64 product-family rates. When you estimate fees with the tool above, include the parcel weight, not just the product’s primary packaging.
What are the penalties if I skip registration?
Three layers. Administrative fines: Germany allows up to €100,000 for a missing registration and up to €200,000 for missing system participation; Spain’s waste-law sanctions for serious infringements start above €10,000. Sales bans: German authorities can prohibit distribution of unregistered packaged goods outright. And the one that bites fastest — marketplace delisting: Amazon, bol and Allegro suspend offers that lack a valid EPR number, so non-registration in practice means losing the sales channel before any regulator writes to you.