EPR compliance isn't a one-time task — it's an ongoing reporting cycle. Miss a deadline and you're late-filing; miss too many and you risk retroactive enforcement. Here's exactly when you file in each market, and how to run a simple compliance calendar.
Most EU EPR systems work on an annual reporting cycle, with fees paid either annually or in quarterly advance instalments. The annual report covers the previous calendar year's packaging volumes. One market — Germany for large producers — adds a mid-year completeness declaration.
| Action | Timing | Notes |
|--------|--------|-------|
| System participation declaration (LUCID update) | January of each year | Confirm ongoing registration; update if company details changed |
| Annual packaging data report to PRO | January–March | Based on previous calendar year (Jan–Dec) |
| PRO invoice and fee payment | Typically Q1 | After PRO processes your annual report |
| Vollständigkeitserklärung (VE) | By 15 May | Only for producers placing >80,000 kg/year — must be auditor-certified |
| Mid-year advance payment | Some PROs: July | Based on estimated H2 volumes |
What most DTC brands actually do: File annual packaging data in January/February for the previous year. Pay the resulting PRO invoice in Q1. No VE required unless you're a large manufacturer. LUCID registration renewal is continuous — no annual renewal, but keep your company data current.
| Action | Timing | Notes |
|--------|--------|-------|
| Annual declaration to Citeo | January–March | For previous calendar year |
| Citeo invoice issued | Typically March–April | Based on declared volumes |
| Payment | Q2 | Or in instalments if agreed |
| Advance declaration for following year | Q3–Q4 | Large producers; Citeo provides estimated volumes based on prior year for smaller producers |
France also uses advance payments: if your volume is predictable, Citeo may invoice quarterly instalments during the year, with a reconciliation at year-end. For small/medium brands, annual billing is standard.
| Action | Timing | Notes |
|--------|--------|-------|
| Annual below-threshold declaration (small producers) | January–March | For previous calendar year |
| Annual data filing (above 50,000 kg) | January–March | Verpact data portal |
| Verpact invoice | Q1–Q2 | Annual billing for most producers |
Below-threshold brands file a simplified declaration with minimal data (just confirming volumes are below threshold). It takes about 15 minutes if your records are in order.
| Action | Timing | Notes |
|--------|--------|-------|
| Annual packaging declaration to Fostplus | January–March | For previous calendar year |
| Fostplus invoice | Q1–Q2 | Annual or quarterly depending on volume |
| Q4 advance declaration | October–November | For large producers: estimated volumes for following year |
Belgium is implementing quarterly fee collection for larger producers from 2026, but most DTC brands at typical volumes will remain on annual billing.
| Action | Timing | Notes |
|--------|--------|-------|
| Annual report to ARA | January–March | Gram-level data per packaging component |
| ARA invoice and payment | Q1–Q2 | Annual billing standard |
| Registration renewal | Not required if no changes | Update if packaging changes significantly |
Austria's gram-level reporting requirement makes the annual report more time-intensive than other markets. Build a buffer — don't start data collection in January; collect it throughout the year or in early December.
| Action | Timing | Notes |
|--------|--------|-------|
| Annual consortium declaration | January–March | Separate declaration per material consortium (COMIECO for paper, COREPLA for plastics, etc.) |
| Consortium invoice and payment | Q1–Q2 | Each consortium invoices separately |
Italy's multi-consortium structure means you may file 2–3 separate declarations (paper, plastics, glass) to different organisations. Keep each consortium's portal credentials on file.
| Action | Timing | Notes |
|--------|--------|-------|
| Annual SRAP declaration | January–March | For previous calendar year |
| Ecoembes invoice | Q2 | Annual billing |
Spain has historically been lightly enforced for small foreign brands, but PPWR alignment is strengthening Ecoembes's enforcement mechanisms.
Here's how the year breaks down for a brand in 5+ EU markets:
December (current year):
January:
February:
March:
April–May:
June–October:
October–November:
December:
Q1 is the crunch. Almost every EU market has an annual filing deadline in Q1. If you have 5 markets, you're filing 5+ declarations in January–March. Brands that don't prepare their packaging data in advance find themselves scrambling to collect weights and order counts in January when they should be filing.
Invoice timing affects cash flow. PRO invoices typically arrive in Q1–Q2. If you're billing annually and have grown significantly year-over-year, the invoice can be larger than expected. Budget for this — don't be surprised by a Citeo invoice in March that's 40% larger than last year because your French revenue grew.
Advance payments smooth the cash flow problem. Most large PROs offer advance payment schedules (quarterly instalments based on estimated volumes). This smooths your EPR cost through the year rather than hitting it all in Q1. Worth asking your PRO about if your EPR bill is becoming material.
From January 2026, France's Citeo Pro scheme is mandatory for B2B packaging. The reporting timeline for Citeo Pro aligns with Citeo household packaging — January–March for the previous year's B2B volumes. If you've only been filing Citeo household reporting, add Citeo Pro to your 2026 calendar.
The simplest approach: a single Google Sheet with:
Set Google Calendar reminders 4 weeks before each deadline. That's enough lead time to collect data and file without rushing.
If you're managing EPR across 5+ countries for the first time, set the December reminder for "start packaging data collection" — it will save significant stress in January.
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