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Packaging EPR: what counts, and as which material
Last checked · 4 min read
Packaging EPR is the obligation virtually every webshop has, because whoever ships something places packaging on the market. The question is not whether it applies to you, but how many kilograms you declare per country and per material. This guide explains which packaging counts, how to classify it, and where to declare it in each country.
- +All packaging that reaches your customer counts: product packaging, multipacks and the shipping box, including void fill and tape.
- +You declare in kilograms per material: paper and board, plastic, glass, metals, wood, beverage cartons, composites.
- +The split between household (to consumers) and commercial (to businesses) decides, in some countries, which organisation you declare to.
- +Every country has its own organisation and threshold: from none in Germany to 50,000 kg in the Netherlands.
Which packaging counts?
For EPR, packaging is anything that wraps, protects or bundles a product and is then thrown away. For a webshop that means three layers:
| Layer | What it is | How it counts |
|---|---|---|
| Primary | The product's own packaging: box, blister, bottle, label, film | Per unit sold |
| Secondary | Packaging that bundles several units, such as a multipack sleeve | Per bundle |
| Shipping | The shipping box or mailer, void fill, tape, packing-slip pouch | Per order, not per unit |
Packaging you buy and use without it reaching a customer, such as the pallets your stock arrives on, usually does not count if you are not the one placing it on the market. When in doubt, ask the organisation in that country.
Classifying by material
Every scheme asks for kilograms per material, because recycling is paid for per material. The split differs slightly by country, but the basis is the same everywhere:
- Paper and board: boxes, inserts, paper void fill, paper tape. Almost always the largest material for webshops.
- Plastic: film, air pillows, blisters, poly mailers, plastic tape.
- Glass: bottles, jars.
- Metals: steel (tin) and aluminium. The Netherlands takes them as one line, Germany and France split them.
- Wood, beverage cartons and composites (combined materials that cannot be separated).
So record weights as finely as you can, per component and per material. Merging for a country that asks for less detail is always possible; splitting for a country that asks for more is not, after the fact.
Household or commercial
Packaging that ends up in consumers' homes is household packaging; packaging that ends up at businesses is commercial or industrial. For a webshop selling to consumers, almost everything is household. If you also sell B2B, the difference matters: in Belgium household packaging goes to Fost Plus and commercial to Valipac, in Germany only packaging that reaches private end users falls under the dual system, and in France Citeo covers household packaging only.
Packaging EPR per country
| Country | Where you declare | Threshold | Guide |
|---|---|---|---|
| Netherlands | Verpact | 50,000 kg per year | Netherlands |
| Belgium | Fost Plus (household), Valipac (commercial) | 300 kg per year | Belgium |
| Germany | LUCID plus a dual system | None | Germany |
| France | Citeo or Léko | No exemption, simplified options for small volumes | France |
Since 12 August 2026 the EU PPWR is the common base under all of these: registration in every member state you deliver to, and an authorised representative where you have no establishment. The national organisations and fees remain.
What is still coming for packaging
The PPWR goes beyond EPR. For webshops these requirements matter most, and they phase in over the coming years:
- Empty space: from 2030, e-commerce packaging may contain no more than 50 percent empty space. A large box for a small product becomes a problem.
- Recyclability: from 2030 all packaging must be recyclable, with fees that depend on how well it recycles.
- EU sorting labels: harmonised labels will eventually replace national marks such as France's Triman.
From sales to kilograms
No marketplace tells you how many kilograms of packaging you sold into Germany. You have to calculate it: units sold per country times packaging weight per unit, plus shipping packaging per order. How to do that accurately, with a worked example, is in calculating packaging weight.
Frequently asked questions
Does the shipping box count for EPR?
Yes. The shipping box, void fill and tape are packaging you place on the market with the customer. Count them per order, not per unit sold.
Do I have to declare packaging my supplier used?
If that packaging reaches your customer with the product, like the product box, yes: you place it on that country's market. Transport packaging that stays with you, such as pallets and outer cartons from your purchasing, usually not.
How precise do the weights need to be?
A kitchen scale is enough: weigh each component once and note the grams. Not forgetting components and counting shipping packaging per order matter more than precision to the gram.
What if packaging combines several materials?
Weigh the parts separately when you can separate them, such as a cardboard box with a plastic window. If they cannot be separated, it usually counts as a composite or as its heaviest material; the rules differ by country.
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This guide is general information, not legal or tax advice. Rules, thresholds and deadlines are set by the schemes themselves and they change. Check what applies to your situation with the scheme or an adviser.