Extended Producer Responsibility (EPR) has long been a cost and compliance issue for FMCG companies - far more than just another form to complete for year-end reporting. This practical guide explains who in your supply chain pays EPR fees for packaging, how to clearly define roles, and how to manage EPR costs based on reliable data.

You will learn:

  • how EPR fees work and what exactly you are paying for,
  • which external parties (manufacturers, importers, retailers, online platforms) are legally responsible,
  • how to determine who is subject to EPR in core markets like Germany and France,
  • how to assign internal responsibilities (procurement, packaging engineering, sustainability, finance),
  • which packaging data you need for EPR transparency - and how digital solutions like the Packa software can help.

With a clear structure, you reduce the risk of fines and market bans, gain control over your EPR costs, and turn regulatory complexity into a competitive advantage.

Further reading: For an overview of how structured packaging data can secure EPR compliance through 2026, see the article "Ensuring EPR Compliance by 2026 - with Structured Data" on the Packa Content Hub: Read now.

Prerequisites: What to clarify before you start

Clarify these aspects in advance:

  • In which countries do you place packaged products on the market (EU-27, UK, Switzerland, others)?
  • Which packaging types do you use?
    • Sales packaging (B2C, B2B)
    • Shipping and e-commerce packaging
    • Secondary and transport packaging
  • How is your supply chain structured?
    • Own production vs. contract fillers
    • Own brands vs. retailers' private labels
    • Direct export vs. distributors/importers
    • Online sales via marketplaces (e.g. Amazon, Zalando)
  • Who owns the trademark rights and which name/brand appears on the packaging?
  • What packaging data is already available?
    • Materials, layer structures, weights
    • Allocation to markets, EANs, brands

The clearer your overview, the easier it is to define EPR roles and costs.

Step 1: Basics - what are EPR fees for packaging?

Extended Producer Responsibility (EPR) is an environmental policy principle that obliges producers to bear the costs for collection, recycling, and disposal of their products - including packaging. In the packaging context, this means: whoever places packaging on the market as a "producer" in a given country finances its disposal and recycling via EPR fees.

Typical process for EPR packaging:

  1. Your company markets packaged goods in a country.
  2. You register as a "producer" in the national register.
  3. You sign a contract with a compliance scheme/PRO (e.g. a dual system, Citeo in France).
  4. You regularly report your packaging volumes (by material, weight, market).
  5. Based on this data, the scheme operator calculates the EPR fees.

Your EPR costs depend on:

  • Type of material (plastic, paper, glass, aluminium)
  • Weight per item and total volume
  • Packaging type (household vs. commercial packaging)
  • Country and fee system
  • Design features (recyclability, recycled content - eco-modulation)

More and more European countries are modulating EPR fees based on the environmental performance of packaging: designs that are easy to recycle are cheaper, while hard-to-recycle formats are more expensive. For FMCG companies, EPR fees are becoming a genuine lever for design and cost, not just a reporting obligation.

Step 2: Understanding external roles - who can legally be the "producer"?

The key question is not who physically manufactures the packaging, but who is considered the "producer" in the respective country.

According to EU guidance, the "producer" is the actor in each member state who is responsible for fulfilling EPR obligations - depending on the setup, this can be the manufacturer, importer, or distributor.

Typical FMCG scenarios:

2.1 Brand owner / manufacturer

  • You produce yourself or via contract fillers.
  • You sell under your brand in the target country.
  • You sell to retail partners, distributors, or end customers.

Consequence: In many countries, you are subject to EPR, regardless of the contract filler or retailer.

2.2 Importer / national distributor

  • Your company imports products and sells them in its home country.
  • A local distributor imports your products into another EU country.

Under German packaging law and the French EPR system, the importer is often the "producer" if the foreign manufacturer has no local entity and the legal responsibility lies with the importer.

2.3 Retailers and online platforms

  • You sell directly abroad via your own online shop.
  • You use marketplaces such as Amazon or Zalando.

Rule of thumb: The retailer that supplies the end customer and is listed as the seller usually bears the EPR obligation. Marketplaces are increasingly checking EPR registration numbers (e.g. LUCID in Germany) and blocking unregistered sellers.

2.4 Private-label arrangements

  • You produce private-label products for a retailer.
  • Only the retailer's brand appears on the packaging.

In many cases: the retailer/brand owner is the "producer". Contractual cost-sharing may differ - but the legal obligation remains with the actor defined as the "producer".

Tip: Create a matrix: sales channel × market × brand owner × responsible party. This makes external EPR obligations visible at a glance.

Step 3: Country-specific responsibilities - examples Germany & France

Every EU member state has its own EPR rules. Two key markets are Germany and France.

3.1 Germany: Packaging Act, LUCID & dual systems

In Germany, under the Packaging Act (VerpackG), the "producer"/first distributor is the party that first places filled packaging on the market on a commercial basis.

Obligations for packaging subject to system participation (mostly B2C sales and shipping packaging):

  1. Registration with the Central Packaging Register (ZSVR) in the LUCID portal
  2. Signing a contract with a dual system
  3. Regular data reporting of packaging placed on the market

Since 1 July 2022, all parties placing packaged goods on the German market are required to register in the LUCID register - regardless of the packaging type.

Who pays the EPR fees?

  • German manufacturer of own brands: the manufacturer itself.
  • Foreign manufacturer without a local subsidiary: the foreign manufacturer, possibly via an authorised representative.
  • German importer: the importer.

Common misconception: "Our packaging supplier handles everything." - Under German law, it is always the first distributor of the filled packaging that is subject to EPR, not the manufacturer of the empty packaging.

3.2 France: Household packaging & Citeo

In France, all companies that place packaged products for French end consumers on the market are subject to EPR. Joining an EPR scheme (e.g. Citeo) is mandatory.

Examples:

  • German FMCG manufacturer selling to French retailers: usually the manufacturer is the "producer".
  • French importer selling German products: the importer is subject to EPR.

France differentiates EPR fees strongly based on design features and recyclability (eco-modulation).

Practical tip: Use the free EPR Fee Guide to compare countries and gain transparency on cost drivers and trends through 2026.

Step 4: Define internal roles & responsibilities within the company

Once it is clear who is externally the "producer", the next step is internal governance:

Recommended role allocation (RACI model):

  • Legal/Compliance - legal interpretation, contract review, monitoring legislation
  • Packaging engineering / R&D - packaging design, specifications
  • Procurement - supplier management, EPR clauses, cost control
  • Sustainability/CSR - recyclability, recycled content, sustainability targets
  • Finance/Controlling - budgeting, accounting, EPR cost analysis
  • Data & IT/Packaging management - packaging data, data quality, reporting

Common problem: Lack of clear ownership leads to delayed registrations, incomplete reporting, and last-minute stress before deadlines.

Practical implementation:

  1. List all EPR-relevant tasks.
  2. Assign an owner and contributors to each task.
  3. Document and embed this governance in your internal control system.

Step 5: Build the data foundation for transparent EPR costs

EPR is fundamentally a data challenge: without structured packaging data, you cannot effectively manage EPR fees, eco-modulation, or risk.

5.1 Minimum requirements for packaging data

For each EPR-relevant packaging unit, capture:

  • Product and packaging ID
  • Market/country
  • Brand and "producer"
  • Material composition, including composites and labels
  • Weights by material and per market
  • Packaging type
  • Information on recyclability and recycled content

In projects, Packa regularly finds that 30-70% of specifications have incomplete or missing packaging data. These gaps hinder EPR reporting and accurate cost calculations.

5.2 The limits of manual Excel spreadsheets

Many FMCG teams rely on:

  • scattered Excel spreadsheets,
  • email queries to suppliers,
  • distributed PDF specifications.

For more than 1,000 SKUs across multiple countries, this quickly leads to:

  • version chaos,
  • transcription errors,
  • missing audit trails,
  • high manual effort.

Digital solutions such as the Packa packaging management software offer:

  • a centralised data repository for specifications
  • AI-supported data capture (Excel, CSV, PDFs, ERP)
  • data gap analysis (e.g. recyclability, EPR-relevant attributes)
  • country-specific EPR logics and fee analyses

The Packa platform enables recycling analyses, CO₂ calculations, and EPR fee management across countries from a single central database.

Tip: Start with a subset of your portfolio (e.g. Germany + top 100 SKUs) and close data gaps there, instead of trying to digitise your entire global portfolio at once.

Talk to Packa

Step 6: Set up a process for EPR fees & reporting - in 6 steps

Structure your EPR process for compliance, and for risk and cost control:

6.1 Define markets & categories

  • Create a list of all countries where you sell packaged goods.
  • Check where EPR obligations apply (within the EU, almost always).
  • Cluster markets by relevance (e.g. top 5 markets covering 80% of volume).

6.2 Assign EPR owners per market

  • Assign a responsible person/entity for each country.
  • Clarify interfaces with finance and sales.

6.3 Clean up the packaging catalogue

  • Consolidate all SKUs and packaging units per market.
  • Reconcile material and weight data with suppliers.
  • Flag all packaging that falls under EPR.

Common mistake: EPR reports are often based on ERP data with incomplete weight information - this leads to incorrect submissions and discussions with compliance schemes.

6.4 Secure registrations & PRO contracts

  • Check whether all legal entities in a country are registered (e.g. in LUCID).
  • Conclude or update system/PRO contracts.
  • Store registration numbers and contracts in a central location.

6.5 Define reporting calendars & workflows

  • Record deadlines for volume reports and payments per country.
  • Plan internal timelines backwards from those deadlines.
  • Set up automated workflows for supplier data and reporting - ideally digital and audit-ready.

6.6 Monitoring, audits & optimisation

  • Implement plausibility checks and data validations.
  • Ensure complete documentation for audits.
  • Use eco-modulation as a design steering tool: simulate how material changes affect EPR costs.

More to explore: Detailed information on eco-modulation and its cost effects is available in the category EPR Fees & Eco-Modulation.

Next steps: From theory to practical EPR management

Key tasks:

  • Clarify external roles: Who is the "producer" in each market?
  • Define internal responsibilities: Who manages EPR within Legal, Packaging, Procurement, Sustainability, and Finance?
  • Build the data foundation: Structured packaging data underpins reliable EPR reporting and cost control.
  • Establish a repeatable process: Clear deadlines, workflows, and auditability.

Recommended next steps:

  1. Hold a kick-off workshop with Packaging, Procurement, Sustainability, and Legal.
  2. Run a quick assessment of your current packaging data (e.g. in 1-2 markets).
  3. Evaluate digital solutions (such as Packa) for integrated EPR management.
  4. Further information: Read "Ensuring EPR Compliance by 2026 - with Structured Data" on contenthub.packa.com.

Companies that understand EPR as a controllable cost and design parameter gain advantages in compliance, efficiency, and cost management.

FAQ: Common questions about EPR fees, roles, and costs

1. Is our packaging supplier or our company responsible for EPR fees?

In almost all EPR systems, the responsible party is not the manufacturer of the empty packaging, but the first distributor of the filled packaging in the respective country. In Germany, this is clearly stated in the Packaging Act. If you supply goods under your own brand, you are usually subject to EPR - regardless of your supplier's registration status.

You can regulate cost sharing contractually, but the legal obligation remains with the "producer".

2. Are there volume thresholds below which we do not have to act?

This varies by country:

  • In Germany: registration in the LUCID register is mandatory regardless of volume. De minimis thresholds apply only to certain reporting requirements.
  • Other countries may have minimum thresholds below which fees or obligations do not apply.

Always check national rules and document your assessment.

3. How strongly do EPR fees affect our packaging costs?

It depends on factors such as:

  • material mix (share of plastic, paper, etc.),
  • weight,
  • recyclability,
  • the respective national fee rates.

Material and design choices - such as hard-to-recycle composites or additional plastic windows - can significantly increase EPR costs in countries with eco-modulation. The EPR share can amount to a material single-digit percentage of your packaging costs - and is trending upwards.

With Packa, you can simulate cost scenarios (e.g. mono- vs. multi-material, recycled content) to support better decisions.

4. How are PPWR and EPR connected?

The upcoming EU Packaging and Packaging Waste Regulation (PPWR) tightens requirements for recyclability, recycled content quotas, labelling, and data availability.

From 12 August 2026, Declarations of Conformity (DoC) and technical documentation will be mandatory for all packaging placed on the EU market.

This directly affects EPR systems and fees:

  • Improved recyclability will often be rewarded with lower fees through eco-modulation.
  • Missing or poor-quality data will make PPWR and EPR compliance more difficult.

Conclusion: PPWR sets the standards, EPR creates the cost and incentive structures.

5. What role does a platform like Packa play in EPR management?

Packa is a specialised packaging management software that centralises packaging data, compliance requirements (PPWR, EPR, PFAS, etc.), and workflows.

For EPR, this means:

  • central data capture of all EPR-relevant packaging attributes
  • automated supplier queries and validation
  • transparent analytics of EPR costs and eco-modulation impacts in each country
  • audit-proof documentation that also supports PPWR requirements

This transforms EPR from an annual "last-minute task" into a continuous management tool for cost, compliance, and sustainability.