EU Compliance · Packaging EPR
EU Packaging EPR Fees Calculator
EU packaging EPR fees are set per country by each national PRO (Citeo, CONAI, LUCID, Ecoembes…) — register per market and pay per material × weight. Estimate yours →
Tariffs last verified 2026-06-13
EPR fee breakdown estimator
material × weight × country| Country / material | kg | €/kg | mod | subtotal |
|---|---|---|---|---|
| FR | ||||
| Plastic | see methodology | €800.00 | ||
| FR subtotal | €800.00 | |||
EU packaging EPR fees are set per country by each national Producer Responsibility Organisation (PRO), not by the EU. Every producer or importer that first places packaged goods on a member state’s market must register with that country’s scheme and pay an annual fee per material (paper/board, plastic, glass, metal, wood, composite) × weight, with eco-modulation by recyclability. France’s Citeo bills by Consumer Sales Units, Italy’s CONAI plastic splits into nine weight bands (~€40–€790/t, revised 1 July 2025), Germany routes through LUCID + competing dual systems, and Spain’s Ecoembes is per-material €/kg. Failing to register is an offence in each market (fines + sales bans). Framework: Packaging & Packaging Waste Regulation (EU) 2025/40, applying from 12 August 2026, which harmonises eco-modulation but keeps fees national. Tariff data verified 2026-06-13.
- LUCID / ZSVR
- Citeo
- CONAI
- Ecoembes
Estimator, not legal advice
Results are orientative estimates for packaging placed on the EU market. They do not constitute tax, legal, or financial advice. Each PRO (Citeo, CONAI, Ecoembes, LUCID and others) sets and publishes its own tariffs; consult a qualified professional 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 | Dual-system price per material × kg; small e-commerce volumes typically start around €50/yr | 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; plastic in 9 bands (~€40–€790/t), import forfait basis €114/t since July 2025 | — |
| 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. Verified 2026-06-13–2026-07; always reconcile against the scheme’s own published tariff 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.
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.
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.
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 does France’s estimate look different from a per-kg figure?
France’s Citeo bills household packaging primarily by the number of Consumer Sales Units (CSUs) placed on the market, not by weight — only graphic paper is pure tonnage. We show France as an orientative weight proxy so you can compare markets, but your real Citeo invoice depends on unit counts. Treat the France figure as a ballpark and confirm against the Citeo barème.
How is Italy’s CONAI plastic contribution calculated?
CONAI does not use one flat plastic rate. The plastic contribution (CAC) is split into nine bands (fasce) by packaging type, ranging from about €40 to €790 per tonne after the revision effective 1 July 2025. A cross-border seller who cannot pre-classify each SKU into a band typically pays the published import forfait basis, which rose from €98 to €114 per tonne on 1 July 2025 — the figure this tool uses for Italy.
Why does Germany show a range instead of a single number?
In Germany you register with LUCID (the packaging register) and then license your packaging with one of about ten competing dual systems, each setting its own per-material price. There is no single official tariff, so we show a market low–high band rather than inventing a false-precision point estimate.
How accurate are these estimates?
They are orientative. Each result cites the PRO source it draws from, and tariffs were last verified 2026-06-13. Spain (Ecoembes) maps cleanly to a per-kg model; France and Italy are structurally per-unit / banded and are shown as proxies. Always reconcile against your PRO’s own calculator before filing. This is not tax, legal, or financial advice.
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 bands and rates above 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.