EPR Packaging Thresholds in Europe — 2025 Compliance Guide
EPR Packaging Thresholds in Europe — 2025 Compliance Guide
EPR Packaging overview across Europe
The European Union and the UK have finally finished implementing EPR packaging regulations. From now, producers are responsible for packaging waste management not only operationally, but financially.
Here are the new packaging EPR thresholds and registration requirements. EU, EEA and UK – all of them – have a different ecology and environmental standards, but target is the same – to save our planet! We’ve also highlighted major updates for 2026 and marked on the calendar key dates so your business will maintain compliance on time.
When EPR rules entered into force
It happened on February 11, 2025 – a new regulation “Packaging and Packaging Waste Regulation (EU 2025/40)” entered into a force. General application starts August 12, 2026.
Key measures under the new EPR regulation also include:
- Recyclability grading from A to C for all packaging.
- Standardized EU labeling system for packaging disposal demands.
- Authorized Representative (AR) necessities for non-EU producers.
These steps serve to unify EU EPR systems and to ease accountability across industries
EPR schemes in 2025
All EU-member states now are running on functional EPR for packaging schemes. So from now on, unity and simplicity are the main characteristics, which describe the process of cross-border compliance under EPR Europe.
Currently, major 2025 days for EPR Schemes are :
- Dansk Producentansvar (DPA) system was showed in Denmark in early 2025.
- Commercial and Industrial (C&I) were expanded EPR to packaging in France and Spain on January 1, 2025.
- PackUK system opened to work in UK on January 21, 2025 and the first invoices issued in October 2025.
- Belgium applies a 300 kg threshold for C&I packaging via Valipac.
And these are only the first steps in the evolution of EPR packaging oversight.
Preparing for the EPR PPWR 2026 Rollout
The PPWR (EU 2025/40) will be prerequisite from August 2026, setting overall recyclability standards and reporting obligations.
How to be up to date for PPWR 2026 Rollout
- Find the country in the table below.
- Register EPR with national PROs (e.g., LUCID.de for Germany).
- Serve annual data by material type and quantity.
- Aim for recyclability grades A–C.
- Set an Authorized Representative for non-EU operations.
How to make EPR registration fast and easy
Use the submit form for a fee quote and get fast registration via live support!
What else will you get?
- Minimized risk of non-accordance.
- Prevent long-term compliance costs.
- Enhance sustainability performance under EPR EU rules.
What are EPR Registration thresholds
The EPR registration threshold can be described as:
Packaging Volume Thresholds
- It depends on the amount of packaging, placed on a national market per year.
- Implements only to packaging sold or introduced in that country.
- When the threshold is 0, registration starts to be required from the first package.
Turnover Thresholds
- These depend on annual sales revenue in the particular country.
- Or applying turnover instead of packaging weight.
- Or registration becomes mandatory right after the limit is exceeded.
When both conditions are presented, producers must meet both thresholds to qualify for EPR registration.
EPR Thresholds in 2025 by countries
| EU Country | Packaging Threshold (kg/year) | Turnover Threshold | Key Notes & 2025 Updates |
|---|---|---|---|
| Austria | 0 | 0 | All packaging requires registration. Split obligations permitted across schemes. |
| Belgium | 300 kg | – | Use Fost Plus (household packaging) or Valipac (C&I). 300 kg threshold applies to C&I packaging only. Belgium has the highest recycling rates in Europe (90%+ C&I). |
| Bulgaria | 0 | 0 | Marking/labeling is required on packaging. |
| Croatia | 0 | 0 | Central government scheme with requirement for a labeling. |
| Cyprus | 0 | – | Verify threshold directly with Green Dot Cyprus. |
| Czech Republic | 300 kg | – | EKO-KOM (monopoly scheme). Contact scheme for current threshold. |
| Denmark | TBD (likely 0 or low) | – | NEW 2025: DPA registration system. |
| Estonia | 25 kg plastic / >50 kg other per quarter | – | ETAD scheme. Verify current requirements. |
| Finland | 0 | €1,000,000 | RINKI scheme. Turnover threshold applies. |
| France | 0 | €10,000,000 | CITEO (main PRO, 95%+ market share). C&I packaging expanded 2025. Triman logo mandatory. No de minimis—single package triggers registration. Simplified reporting available under 10,000 units. |
| Germany | 0 | 0 | LUCID register (free, mandatory). Multiple PROs available (e.g., BellandVision, Interzero, Der Grüne Punkt). No threshold—even one package requires registration. Fees start ~€25/year. Audited declaration required above specific material thresholds. |
| Greece | 0 | 0 | EPR registration mandatory for all packaging. |
| Hungary | 0 | 0 | Central scheme. Product fee alternative available. |
| Ireland | 10,000 kg | €1,000,000 | Repak (dominant PRO). Both thresholds must be met. Voluntary registration available below thresholds. |
| Italy | – | €200,000 | CONAI (mandatory consortium). Turnover-based threshold. Three compliance schemes available. |
| Latvia | 300 kg | – | Verify threshold with national scheme operator. |
| Lithuania | 500 kg | – | GPAIS register. Labeling requirements apply. |
| Luxembourg | 0 | 0 | Industrial packaging mandatory from 2025. |
| Malta | 100 kg | 0 | Labeling mandatory. Verify packaging threshold. |
| Netherlands | 50,000 kg | – | Nedpack/Afvalfonds scheme. CRITICAL EXCEPTION: 50,000 kg threshold does not apply to single-use plastics (SUP) or beverage containers subject to deposit schemes—these require immediate registration regardless of weight. Generally lower fees than other countries. |
| Poland | 0 | 0 | Multi-PRO system (e.g., Rekopol). All packaging requires registration. |
| Portugal | 0 | 0 | Labeling mandatory from 2025. Multiple PRO options. |
| Romania | 0 | 0 | EPR registration required for all packaging. |
| Slovakia | 0 | 0 | Six approved schemes. Individual (non-PRO) compliance permitted for non-household packaging. |
| Slovenia | 0 | 0 | Ministry certification required for individual compliance. |
| Spain | 0 | 0 | Ecoembes (main PRO). C&I packaging expanded January 1, 2025. Labeling requirements apply. |
| Sweden | 0 | 0 | Materialretur (or FTI). High compliance fees. All packaging requires registration. |
| UK | 25,000 kg (small) / 50,000+ kg (large) | £1,000,000 – £2,000,000 | PackUK system. Small producers: £1–2M turnover OR 25–50 tonnes. Large producers: £2M+ turnover AND 50+ tonnes. First fees invoiced October 2025 for 2024 data. |
Examples of Key National EPR Systems
EPR Packaging Germany
All producers are required to register through LUCID, even for a one single package. Multiple PROs exist, including Interzero and BellandVision.
Annual declarations are required with audition above material thresholds.
EPR Packaging France
Under CITEO, producers register regardless of quantity. C&I packaging became mandatory in 2025. The Triman label must appear on all consumer packaging.
UK EPR for Packaging
The PackUK platform defines producers by size depending on turnover and packaging weight. First invoices will be issued in October 2025 for 2024 data.
Penalties for Non-Compliance with EPR Regulations
Sanctions for breaching EPR regulation are corresponding for each country, for example:
- Germany: Fines up to €200,000 sales bans and platform insolvency.
- France: Fines up to €30,000 per offense and online sales restrictions.
- UK: Civil sanctions and possible trading prohibitions.
- EU-wide: Customs holds and loss of competitive access.
Pliability ensures continuous market access and protects company reputation.
Get a fee quote for Multi-Country Registration
Managing EPR packaging across several countries can be hard to understand. Please fill up a fee quote with Lovat simplifies EU-wide EPR registration, data reporting, and ongoing compliance.
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