Extended Producer Responsibility (EPR) is the principle that whoever puts packaging on the market pays for collecting and treating it at end-of-life. In the EU, every Member State runs its own EPR scheme, with its own rules, fees, declaration formats, and deadlines. For a producer selling into multiple markets, the operational reality is: same packaging, six different reporting workflows.
This guide walks through the three biggest EU markets — Germany, France, and the Netherlands — what each one requires, where they differ, and what producers consistently get wrong.
The Netherlands: Afvalfonds Verpakkingen
The Dutch EPR scheme is run by Afvalfonds Verpakkingen, funded through fees collected from producers placing packaging on the Dutch market. Reporting is annual; fees are calculated against weight placed on market by material type.
What you submit:
- Annual declaration of packaging tonnage placed on the Dutch market
- Breakdown by material category: paper/cardboard, plastic, glass, metal, wood, biodegradable, composite
- Distinction between business-to-consumer and business-to-business packaging
- Producer identification and Chamber of Commerce details
The Dutch scheme has historically been one of the lighter-touch EPR regimes. That is changing. Recent updates require more granular reporting and add modulated fees for non-recyclable materials. By 2026 the Dutch declaration looks materially different from the simpler 2022 version.
Common producer mistake: Treating Afvalfonds reporting as a finance task and not a packaging-data task. The fee calculation looks simple until you have to defend the underlying tonnage figures during a sample audit.
Germany: Zentrale Stelle and the LUCID register
Germany's EPR scheme is significantly more demanding. The Verpackungsgesetz (German Packaging Act) requires that producers register in the LUCID register run by Zentrale Stelle Verpackungsregister before placing any packaging on the German market.
What you have to do:
- Register in LUCID with full producer details. Registration is per legal entity, not per brand.
- License with a system operator (a "duales System" — Der Grüne Punkt, Interzero, Reclay, etc.) that handles the actual collection.
- Submit declarations of packaging tonnage to LUCID, broken down by material type and packaging form.
- Pay licence fees to your system operator, modulated by material recyclability.
- Comply with takeback obligations for packaging that's not part of the dual system (B2B packaging, transport packaging, etc.).
Germany's modulation is real. Highly recyclable packaging pays fees that are sometimes one-third of what a non-recyclable equivalent pays, and the gap is widening. PPWR Article 6 grades will increasingly drive German EPR fees.
Common producer mistake: Selling into Germany via a fulfilment marketplace and assuming the marketplace handles registration. They don't. The producer is the entity that first places the packaging on the German market, and the obligation is theirs even if Amazon or another fulfilment service handles distribution.
France: CITEO and the unique identifier
France's EPR scheme is run primarily by CITEO (formerly Eco-Emballages and Ecofolio merged). Producers contract with CITEO, declare tonnage, and pay fees that are heavily modulated by recyclability and recycled-content performance.
The French system has two distinguishing features:
- The unique identifier requirement. Producers must declare a unique identifier number on packaging, demonstrating registration with the EPR scheme. This is enforced more strictly than in most other markets.
- Bonus-malus modulation at scale. Recyclable, mono-material, recycled-content-rich packaging earns bonuses (fee reductions). Multi-material, problematic, or hard-to-recycle packaging incurs maluses (fee increases). The bonus-malus delta can be 50% or more of the base fee.
France has also been the EU's most aggressive on enforcement. Penalties for missing or false declarations are significant.
Common producer mistake: Underdeclaring on the assumption that French enforcement is light. It isn't — and CITEO conducts cross-checks against import data and supplier deliveries. Producers who underdeclared in 2023-2024 are receiving back-payment notices in 2026.
Where the markets differ — and what that means for you
| Dimension | Netherlands | Germany | France |
|---|---|---|---|
| Pre-market registration | Not required | LUCID mandatory | CITEO contract mandatory |
| Declaration frequency | Annual | Annual + monthly system reports | Annual + adjustments |
| Granularity | Material category | Material + packaging form | Material + recyclability |
| Fee modulation | Light (increasing) | Significant | Heavy bonus-malus |
| Enforcement intensity | Moderate | High | Very high |
| Audit risk | Sample-based | Targeted + sample | Frequent cross-checks |
The data model that survives all six markets
The trap producers fall into is building a separate data setup per market. Three EPR schemes, three spreadsheets, three reconciliation workflows. The reconciliation alone consumes more time than the actual reporting.
The producers who handle multi-market EPR efficiently have one underlying packaging dataset, with rules engines per market that derive the local declaration format from the same source. Same SKU, same packaging composition, same weight, three derived declarations.
This is non-trivial to build, which is why most producers either pay a consultancy per market or use a platform that handles it. PackR8's multi-market EPR module covers the three markets above plus Belgium (Fost Plus), Spain (Ecoembes), Italy (CONAI), and Poland — from the same underlying data. See how it works.
What's coming next
EU EPR is converging, slowly, toward harmonised modulation criteria — driven primarily by PPWR Article 6 grades. By 2030, the difference between Member State EPR systems will narrow, and the underlying data each one consumes will become more similar.
That convergence will reward producers with structured packaging data and penalise those without. The current era of bespoke market-specific workflows is ending. The producers who get ahead of this convergence will spend the next decade optimising; those who don't will spend it reconciling.