EPR for packaging — who pays, and where

Extended producer responsibility means that whoever puts packaging onto a national market pays for collecting and recycling it. The principle is European. The registers, the thresholds, the fees and the deadlines are national, and they differ enough that a company selling into four countries has four sets of obligations.

PPWR harmonised the structure. It did not create one register.

The question that decides everything

Who places the packaging on the market?

Not who made it, not who owns the brand — who first makes it available in that country. For a packaging buyer there are usually two answers, and they are both right at once for different things:

Packaging	Placed on the market by
The sacks, boxes and film you buy and then sell on or use to pack your own goods	You, in the country where you sell
The pallets and stretch film the delivery arrives on	The plant that shipped it, in the country it shipped to

The second line is the one people miss. Transport packaging under a consignment is placed on the destination market by whoever sent it, which on a direct factory shipment is the plant — not you, and not the agent who arranged the specification. Ask the plant to confirm its registration before the first order, because you will be asked for it eventually and it is easier to establish now.

Sales packaging or transport packaging

The distinction runs through every national scheme and it changes both the cost and the paperwork.

Sales packaging — packaging that reaches a private final consumer. It carries the heaviest obligations: registration, a contract with a collection scheme, volume reporting, and a per-kilo fee that is a real cost.

Transport and industrial packaging — packaging between businesses that never reaches a household. Usually still registrable, usually not subject to a collection-scheme contract, and generally handled through take-back arrangements instead.

Most of what this business sells is the second kind. Bin liners sold to a cleaning contractor, pallets moving goods between two warehouses and stretch film on a factory floor are business-to-business packaging, and treating them as sales packaging is an expensive misreading that some schemes’ own online forms encourage.

The exception that catches people: the same product sold through a retailer to a consumer becomes sales packaging. A 20-pack of bin liners on a supermarket shelf is not the same obligation as a pallet of the identical sacks delivered to a facilities company.

What it costs, roughly

Fees are per kilogram of packaging placed on the market, by material, and they vary by country and by year. Plastic film is typically the most expensive material per kilo; paper and board are among the cheapest; wood is usually cheapest of all.

That ordering is stable even when the numbers are not, and it has a practical consequence: reducing plastic packaging weight reduces EPR cost roughly in proportion, which is the rare case where the compliance incentive and the freight incentive point the same way.

By country

• Germany — LUCID registration, the dual system, and why transport packaging is treated differently.
• Netherlands — Verpact, the weight threshold, and annual reporting.

Other European markets each have their own register — Belgium, Austria, France, the Nordics. Ask us for the specifics of yours and we will tell you what we know and what you should confirm with your own adviser.

What we do, and what we do not

We do:

• get the material and weight of packaging stated on the quotation and the delivery note, which is what your own reporting needs,
• get the figures broken down by material, in the format your scheme asks for,
• establish before you order whether the plant is registered in your market for the transport packaging it sends, and get that in writing.

We do not:

• register on your behalf, or on the plant’s. It is a legal identity making a declaration, and anybody offering to do it for you is offering something they cannot be responsible for,
• give legal advice about your obligations.

The material and weight breakdown is the useful part, and it is the part most suppliers do not give. EPR reporting is a weight-by-material exercise, and a delivery note that says “1 pallet, 40 cases” is no help at all when the return is due.

What this means for what you buy

EPR is reported by material and weight, which makes it a question about the specification rather than about the supplier. Every quotation we obtain carries packaging weights broken down by material, for stretch film, bin liners and catering film alike, because that is the figure your return needs and the one nobody sends unless asked.