If you're selling to customers in Germany, France, and the Netherlands, you have three separate EPR bills to pay — with different rates, different material categories, and different PROs. Here's a direct comparison to help you understand where your fee exposure is highest and plan your compliance budget.
Rates below are indicative for 2026. Official rates are published annually by each PRO and can vary within ranges based on eco-modulation adjustments.
| Material | Germany | France (Citeo) | Netherlands (Verpact) |
|----------|---------|----------------|----------------------|
| Corrugated cardboard (uncoated) | €60–€85/t | €105–€140/t | €75–€110/t |
| Coated/laminated cardboard | €80–€100/t | €120–€165/t | €85–€120/t |
| Kraft paper | €55–€80/t | €100–€135/t | €70–€100/t |
France charges the highest rates for paper and cardboard of these three markets. If you're shipping a lot of cardboard boxes to French customers, this is your largest absolute cost in France.
| Material | Germany | France (Citeo) | Netherlands (Verpact) |
|----------|---------|----------------|----------------------|
| PET bottles (clear) | €100–€150/t | €170–€230/t | €130–€180/t |
| HDPE rigid (natural/clear) | €110–€160/t | €180–€250/t | €140–€200/t |
| PP rigid containers | €130–€190/t | €220–€300/t | €160–€220/t |
| LDPE / PE film (polybags, wrap) | €180–€260/t | €300–€400/t | €200–€280/t |
| EPS (foam) | €200–€300/t | €350–€500/t+ | €240–€320/t |
| Multi-layer flexible film | €200–€280/t | €320–€450/t | €220–€290/t |
Key observations:
| Material | Germany | France (Citeo) | Netherlands (Verpact) |
|----------|---------|----------------|----------------------|
| Clear glass | €8–€18/t | €12–€22/t | €8–€15/t |
| Coloured glass | €10–€22/t | €15–€28/t | €10–€18/t |
Glass rates are similar across markets and low in absolute terms. Glass brands (wine, spirits, beauty) will find the Netherlands has the cheapest glass rates of the three.
| Material | Germany | France (Citeo) | Netherlands (Verpact) |
|----------|---------|----------------|----------------------|
| Steel (tins, cans) | €30–€55/t | €55–€80/t | €40–€65/t |
| Aluminium | €55–€90/t | €85–€120/t | €65–€95/t |
Again, France is the most expensive, though metal packaging is rarely a dominant cost driver for DTC brands.
A crucial difference: the Netherlands has a 50,000 kg collective participation threshold. Below that, you register and file a declaration but pay no participation fees to Verpact.
For most DTC brands, the Netherlands has zero EPR fees until you reach 50,000 kg/year of packaging — roughly equivalent to shipping ~165,000+ orders with 300g average packaging per order. Most Shopify brands are well below this.
Germany has a 50 kg threshold — reached within a few hundred shipments. France has no threshold. So for small brands entering three markets simultaneously, Germany and France generate immediate EPR fee liability; Netherlands does not.
Brand: A premium skincare brand launching in DE, FR, NL
Packaging per order:
Annual orders to each market: 8,000 DE / 5,000 FR / 3,000 NL
Step 1: Annual kg by material by country
| Material | DE (8,000 orders) | FR (5,000 orders) | NL (3,000 orders) |
|----------|------------------|--------------------|-------------------|
| Glass | 640 kg | 400 kg | 240 kg |
| Cardboard | 2,000 kg | 1,250 kg | 750 kg |
| Paper | 400 kg | 250 kg | 150 kg |
Step 2: Apply midpoint rates
Germany:
France:
Netherlands (3,000 orders × 300g = 900 kg total — well below 50,000 kg threshold):
Total EPR bill for this brand: ~€372/year
This is below most people's expectations. EPR fees are genuinely not a major cost for most DTC brands at typical volumes.
EPR costs become material at scale:
At 50,000 orders/year to Germany (with 300g/order = 15,000 kg cardboard equivalent):
At 100,000 orders/year across DE/FR:
Brands using heavy plastic packaging (poly mailers, pouches) see higher costs earlier because plastic rates are 2–3x cardboard rates.
The real threshold where EPR becomes a board-level line item is typically €50M+ annual EU e-commerce revenue. Below that, it's a compliance item, not a margin driver.
All EU EPR rates are increasing. The PPWR drives this through several mechanisms:
Rates increased 10–25% on average across these three markets from 2023 to 2026. Expect similar increases through 2030.
Budget for growth: EPR fees scale with volume. If you're projecting 3x EU revenue growth, budget 3x EPR fees.
Model eco-modulation: If you're using LDPE polybags for any market, get a quote from Citeo or a French PRO — your France fees will be higher than this comparison suggests.
Netherlands threshold awareness: If you're approaching 50,000 kg in Netherlands, get ready for fees that appear suddenly. Model the breakeven point.
PRO shopping in Germany: Germany has multiple competing PROs with genuinely different rates. Get three quotes before committing. Rate differences of 10–20% are common.
---
For the full 7-market picture, see our expert article on EPR cost modelling across 7 EU markets.