The most common question from e-commerce brands new to EPR: "Do I actually have to do this, or can I ignore it?"
The honest answer is: it depends on how much you're selling and in which countries. Most DTC brands above €500k EU revenue are already obligated in their top markets. Below that, it gets more nuanced.
Here's how to work it out.
Every EU country sets its own EPR thresholds. Below a certain level of packaging volume or revenue, you're exempt. Above it, you must register and report.
The thresholds are defined by:
Here's the problem: these aren't uniform. Germany uses one approach, France uses another, Italy uses a third. You need to check each market independently.
Threshold: 25 kg of glass packaging OR 50 kg of any other material per year placed on the German market.
In practice, most brands hit 50 kg of cardboard/paper or plastic within a few hundred orders. A standard e-commerce order with a cardboard box, tissue paper, and a polybag typically weighs 150–400g of packaging. At 400 orders/year into Germany, you're likely over threshold.
What triggers it: Selling directly to German consumers (B2C) via your own website, Amazon.de, or any other channel.
Exemption: Brands placing less than 25 kg of glass or 50 kg of other materials per year in Germany are exempt. Micro-enterprises (under EU definition) with less than 1,000 kg of packaging per year have some relief under the new PPWR framework, but the German LUCID register has its own rules — when in doubt, register.
Register: LUCID Verpackungsregister — registration is free. You pay fees to your chosen PRO, not to the register itself.
Threshold: No explicit weight threshold for most categories — if you place household packaging on the French market (B2C), you are obligated regardless of volume.
Exception: There is a small producer exemption for companies with fewer than 10 employees AND annual turnover under €2M. If you're above either of those figures and selling to French consumers, you must register with Citeo.
B2B packaging (shipping to businesses, not consumers) falls under Citeo Pro from 1 January 2026 — a separate scheme specifically for B2B packaging flows.
Register: Citeo Producer Portal — registration required before placing products on the French market.
Threshold: 50,000 kg of packaging per year placed on the Dutch market.
This is a high threshold. Most DTC e-commerce brands selling into the Netherlands from outside will be well below it. However: brands below the threshold are still required to report their packaging data (a lightweight "registration" is required), and brands above it must also join the collective PRO scheme.
Important nuance: Even below-threshold brands must keep records in case of audit. Dutch enforcement has intensified since 2024.
Register: Via Nedvang or through a PRO such as Verpact.
Threshold: 0 — there is no de minimis threshold in Italy. Any producer placing packaging on the Italian market must register with CONAI.
Italy is therefore the strictest on paper, though enforcement against small foreign brands has historically been lighter than Germany or France.
Material consortia: Italy operates through material-specific consortia under CONAI — Comieco (paper/board), Corepla (plastics), Ricrea (steel), CiAl (aluminium), Rilegno (wood), Coreve (glass). You may need to engage multiple consortia depending on your packaging mix.
Register: CONAI — foreign producers must appoint an Italian authorised representative.
Threshold: No de minimis threshold for B2C packaging. Any producer placing household packaging on the Spanish market must register with Ecoembes.
B2B packaging (corrugated, pallets, etc.) falls under Ecoembalajes España — a separate scheme.
Register: Ecoembes — registration required. Foreign brands typically work through an authorised representative.
Threshold: 300 kg of household packaging per year for Fostplus. Below this, a simplified declaration is still required but fees are lower.
Belgium has two relevant schemes:
Most DTC brands only need Fostplus unless they also ship in bulk B2B.
Register: Fostplus
Threshold: No de minimis for packaging placed on the Austrian consumer market. The ARA (Altstoff Recycling Austria) system requires registration from all producers.
Practical note: Austria uses a gram-level fee calculation — more granular than most other markets. You'll need accurate per-SKU packaging weight data.
Register: ARA
Under the new PPWR (Regulation EU 2025/40), micro-enterprises — defined as companies with fewer than 10 employees and annual turnover or balance sheet under €2M — placing less than 1,000 kg of packaging per year per market are exempt from re-use targets. However, they are not exempt from EPR registration and fee obligations in most countries. The micro-enterprise exemption is narrower than most brands assume.
Ask yourself these questions:
If you're unsure, err on the side of registering. The cost of registration is trivial compared to the cost of a retroactive audit.
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Next: What counts as "packaging" under EU law? — because the definition is broader than most brands expect.