Packaging EPR in 2026: what’s changing across Europe (fees, scope, audits, and marketplaces)

This article breaks down what’s changing, what it looks like in practice, and what to do now—using simple examples you’ll recognise.

1) A quick refresher: what packaging EPR actually regulates

Packaging EPR makes the business that “places packaging on the market” financially (and sometimes operationally) responsible for what happens to that packaging as waste.

In practice, EPR obligations usually include:

• deciding if you’re the “producer” in-scope (brand owner vs importer vs distance seller vs distributor)
• registering with a national producer register and/or joining a Producer Responsibility Organisation (PRO)
• reporting packaging quantities by material and format for each country
• paying fees (often with incentives or penalties linked to packaging design)
• keeping evidence to defend your data if audited

The big trend is clear: more data granularity, more accountability, and more cost linked to packaging outcomes.

2) Why EPR is tightening in 2026 (and why it’s not “just reporting” anymore)

Three forces are driving the shift:

A) Packaging rules are becoming more harmonised

European packaging policy is moving toward more consistent requirements, with tighter expectations around recyclability, labelling, and proof. Even where EPR remains nationally managed, many countries are aligning their systems with EU-level direction.

B) EPR is being used to change packaging behaviour

EPR is no longer only about funding waste management—it’s increasingly designed to steer packaging design decisions. The result is fee systems that can reward better packaging and penalise harder-to-recycle formats.

C) Enforcement is catching up with reality (especially e-commerce)

Authorities are paying more attention to “missing producers,” cross-border sales, and high-volume parcel flows. This makes it harder for distance sellers and non-EU operators to remain invisible.

3) Recent developments that are shaping 2026 compliance (what this looks like on the ground)

Development 1 — New markets are turning on full EPR systems

Some countries are finalising and activating packaging EPR frameworks that global brands historically overlooked. When these systems go live, businesses discover late that “we’re compliant in the EU” doesn’t automatically mean “we’re compliant everywhere we sell.”

What this means for you: if you sell across Europe, you need a country-by-country view. Missing “small markets” can become expensive fast once enforcement and invoicing begin.

Development 2 — “Professional/B2B packaging” is getting more attention

Several markets are moving beyond “household packaging only” thinking. Packaging used or discarded by businesses—transport packaging, industrial packs, large cartons, pallet wrap—can increasingly fall into regulated scope.

What this means for you: if you sell B2B, or ship pallets into the EU, you may have obligations even if you don’t sell consumer products.

Development 3 — Fees are becoming material, and finance teams are asking questions

As fee structures mature, EPR is turning into a predictable cost line—one that procurement and finance want forecasted, reduced, and controlled.

What this means for you: packaging design choices (material, format, weight) can directly shift compliance cost, sometimes significantly at scale.

Development 4 — Cross-border selling is becoming a compliance hotspot

More scrutiny on cross-border parcels and online sales increases the visibility of who is placing packaged goods on the market. This increases the pressure on distance sellers, importers, and marketplace sellers to prove their registrations and reporting are real—not assumed.

What this means for you: e-commerce + cross-border selling requires extra clarity on who the obligated entity is, and where.

4) What “tougher EPR” looks like inside a business

A) Scope expands, and your packaging inventory must expand with it

Common blind spots include:

• shipping packaging for D2C (mailers, void fill, tape)
• secondary packaging (multipacks, outers)
• tertiary/transport packaging (stretch wrap, straps, pallets), especially for B2B
• inserts and added materials during fulfilment or repacking

If your internal packaging dataset only covers “the product pack,” you may be under-reporting.

B) Eco-modulation means design choices can change your fees

Eco-modulation is the idea that EPR fees vary depending on packaging attributes—typically recyclability and sometimes format or material composition. This turns packaging design into a cost lever.

Practical impact: two packaging options that look similar to a consumer can create very different fee outcomes for your business.

C) Audits become easier when your data is weak

The most common triggers are:

• inconsistent classification (especially composites/laminates)
• weak or missing weights
• sudden jumps in volumes
• mismatch between sales/shipping volumes and reported packaging
• unclear responsibility between brand owner, importer, distributor, and marketplace seller

If you can’t explain your EPR numbers, you can’t defend them.

5) Three examples you can relate to (what changes in 2026)

Example 1 — A cosmetics brand selling D2C across Europe

Scenario: a non-EU cosmetics brand sells online directly to consumers in multiple EU countries.

What goes wrong: the company registers in a few large markets but misses a smaller country where packaging EPR is now actively enforced. They also forget to include shipping materials in reports (mailers, fillers, tape).

What “good” looks like:

• assign producer responsibility per country and channel
• register correctly before launching sales
• report both product packaging and shipping packaging
• keep an evidence pack: component weights, materials, supplier specs

Outcome: fewer surprises when enforcement or invoices land.

Example 2 — A B2B supplier shipping pallets into the EU

Scenario: a B2B industrial supplier ships to EU customers using pallets, stretch wrap, straps, and large cartons.

What changes: professional/B2B packaging becomes more clearly regulated in certain markets, increasing the likelihood that this supplier is obligated even though they don’t sell consumer goods.

What “good” looks like:

• track tertiary packaging (wrap, straps, pallets) as part of the packaging inventory
• define who is placing the packaging on the market (importer vs local entity vs distributor)
• set up shipment-level packaging tracking for EU-bound deliveries

Outcome: you avoid being “accidentally non-compliant” due to blind spots.

Example 3 — A food manufacturer with high-volume plastic formats

Scenario: a food producer uses trays, films, and multi-component packs at high volume.

What changes: as fees and modulation mature, packaging cost exposure becomes large enough to demand action.

What “good” looks like:

• validate weights and material mapping (especially composites)
• remove non-essential components where possible
• prioritise redesigns that reduce tonnage and improve recyclability
• build a clear internal model linking packaging design choices to EPR cost

Outcome: EPR becomes a managed cost line, not a shock invoice.

6) The 2026 EPR readiness checklist

If you’re behind, focus on speed and defensibility:

Step 1 — Build a packaging master list (SKU → packaging components)

For each SKU / ship unit, list:

• primary pack components (container, cap, label, sleeve, liner)
• secondary packaging (multipacks, cartons)
• shipping packaging (mailers, void fill, tape for D2C)
• tertiary/transport packaging (wrap, straps, pallets), where relevant

Step 2 — Assign responsibility by country and channel

For each market:

• who is the obligated entity (brand owner, importer, distance seller)?
• what’s the route to market (retail, distributor, marketplace, D2C)?
• who is registering and reporting—and can they prove it?

Step 3 — Lock an evidence trail

Minimum evidence set:

• component weights (measured or supplier-certified)
• material specifications (especially composites)
• methodology: how you convert units sold/shipped into packaging placed on market
• records of registration IDs, reporting submissions, and invoices

Step 4 — Forecast fees and find design levers

• model costs by material and tonnage
• identify heavy and expensive formats
• prioritise redesign opportunities (downgauging, mono-material moves, component reduction)

Step 5 — Treat e-commerce as a high-risk channel

• confirm importer-of-record and responsible entity
• avoid “nobody owns compliance” situations between seller, marketplace, and fulfilment partner
• ensure shipping packaging is captured, not forgotten

Conclusion: packaging EPR is becoming “pay, prove, and optimise”

In 2026, the most common EPR failures won’t be “we didn’t know EPR existed.” They’ll be:

• we didn’t track the right packaging (especially shipping and transport materials)
• we reported, but our data wasn’t defensible
• we paid, but didn’t realise design decisions were driving cost
• we sold cross-border, but responsibility was unclear

The winners will treat EPR like a real compliance system: clear scope, accurate data, audit-ready proof, and design-led cost control.

FAQ: Packaging EPR in Europe (2026)

1) Who is the “producer” under packaging EPR?

It depends on the country and the supply chain setup, but in most systems the “producer” is typically:

• the brand owner / packer-filler established in the country, or
• the importer (if the brand owner isn’t established locally), or
• in some cases, the distance seller for cross-border e-commerce

Practical tip: don’t assume your distributor or fulfilment partner “covers EPR” unless it’s written into contracts and backed by proof (registration numbers, reporting copies, invoices).

2) We sell on Amazon / marketplaces. Are we automatically compliant?

No. Marketplaces sometimes offer compliance services, but responsibility can still sit with:

• you (brand owner / seller), or
• your importer-of-record, or
• another obligated entity depending on local rules and how goods enter the market

A good internal check: for every country you sell into, answer “who is legally placing the packaging on the market?” If the answer is unclear, that’s a compliance gap.

3) What packaging do we need to count for EPR reporting?

At minimum, expect to count:

• primary packaging (the product pack)
• secondary packaging (multipacks, cartons)
• shipping packaging (mailers, void fill, tape for D2C/e-commerce)

And in many cases (or increasingly), also:

• tertiary/transport packaging (pallet wrap, straps, pallets), especially for B2B setups

Common mistake: companies track only consumer packaging and forget shipping + transport materials that can be material in tonnage and fees.

4) What’s changing in 2026 that makes EPR “tougher”?

Three things:

• higher cost exposure (fees rising; cost visibility increasing)
• scope expansion (more attention on B2B/professional packaging in some markets)
• enforcement visibility (more structured registers, more cross-border scrutiny, and more pressure on e-commerce flows)

5) What is “eco-modulation” and why does it matter?

Eco-modulation means EPR fees can change based on packaging design outcomes—typically recyclability, material choices, and sometimes format.

Why it matters:

• it turns packaging design into a direct cost lever
• two packaging formats with similar function can produce very different compliance costs
• finance teams will increasingly ask: “Can we reduce fees by redesigning?”

6) What evidence do we need to keep to survive an EPR audit?

Aim for “audit-ready,” not “marketing-ready.” Minimum:

• SKU-level bill of materials (components + materials)
• weights by component (measured or supplier-certified)
• material specs (especially composites/laminates)
• methodology for converting units sold/shipped into packaging placed on market
• supplier declarations that support material composition and claims

If you can’t reproduce your numbers later, you’re exposed.

7) We don’t have exact weights for every SKU. What’s the fastest safe approach?

Use a tiered approach:

• Tier 1: top-selling SKUs + heaviest packs (measure first)
• Tier 2: “pack families” (representative weights for similar SKUs)
• Tier 3: long-tail SKUs (conservative estimates, then refine)

Keep measurement records and document assumptions so the approach remains defensible.

8) How do we handle composite or multi-material packaging in reporting?

This is where most errors happen.

Good practice:

• break down components (bottle, cap, label, pump, sleeve, liner)
• classify each component by material based on supplier specs
• avoid guessing based on appearance

Where a laminate is inseparable, record the best available breakdown and store the supporting documents.

9) What’s the difference between household packaging EPR and professional/B2B packaging EPR?

Household EPR covers packaging that ends up with consumers. Professional/B2B EPR covers packaging used or discarded by businesses (transport packs, industrial packaging, large-format commercial packaging).

Why it matters:

• you can be obligated even if you don’t sell consumer products
• packaging you never tracked before (wrap, pallets, big cartons) can become reportable

10) How often do we have to report and pay?

It varies by country and your volume:

• annual reporting in some schemes
• quarterly reporting in others
• monthly reporting for higher-volume operators in certain systems

The general trend is more structured cadence rules and more frequent reporting for high-volume operators.

11) We use fulfilment warehouses in the EU. Does that change our EPR position?

It can, because it affects:

• where packaging is placed on the market
• who the importer-of-record is
• whether local entities become obligated

If fulfilment includes repacking, relabelling, or adding inserts, your packaging footprint can increase because you’re adding packaging on-market.

12) What are the top 5 EPR mistakes that trigger cost and enforcement risk?

• missing “small” markets that later become active enforcement targets
• under-reporting by ignoring shipping + transport packaging
• weak weights and no evidence trail
• misclassifying composites/laminates
• unclear responsibility split between brand owner, importer, marketplace seller, and distributor

13) What should we do this week if we’re behind?

A fast recovery plan:

• build a matrix: markets × legal entity × channel
• create a packaging master list for top SKUs (primary + shipping)
• measure weights for your top 20–50 SKUs
• demand proof of who registers and reports (IDs, submissions, invoices)
• start a single “source of truth” folder for evidence (BOMs, supplier specs, declarations)