EPR compliance documents are full of acronyms, legal shorthand, and German compound words. Here are 30 terms you'll encounter — defined clearly, with enough context to actually use them.
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EPR — Extended Producer Responsibility
The legal principle that brands (producers) are responsible for the end-of-life management of their packaging. EPR shifts the cost of collection and recycling from taxpayers to the companies that put packaging on the market.
PPWR — Packaging and Packaging Waste Regulation
Regulation (EU) 2025/40. The EU legislation that replaces the old Packaging Directive and sets new mandatory rules for packaging recyclability, recycled content, re-use, and EPR. In force from 11 February 2025; most obligations apply from 12 August 2026.
Producer
Any business that places packaging on the market for the first time in an EU country. This includes brands selling B2C from their webshop, importers, and marketplace sellers. If you ship a box to a customer in Germany, you're a producer in Germany.
Placing on the market
The act of making packaged products available in an EU member state for the first time. This is what triggers EPR obligations — the moment a product with packaging enters an EU country's supply chain destined for consumers.
PRO — Producer Responsibility Organisation
The licensed body that manages packaging waste collection and recycling on behalf of producers. Brands pay EPR fees to their PRO; the PRO funds the recycling infrastructure. One PRO per country (sometimes multiple competing PROs, as in Germany).
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LUCID
Germany's central packaging register (Lizenzierungs- und Überwachungs-Datenbank), operated by the ZSVR. All brands placing packaging on the German market must register and receive a LUCID number.
ZSVR
Zentrale Stelle Verpackungsregister. The German authority that operates LUCID and enforces compliance with the German Packaging Act.
VerpackG
Verpackungsgesetz. Germany's Packaging Act, enacted 2019, establishing the LUCID registration requirement and EPR fee obligations.
Citeo
France's main PRO for household packaging. Manages collection and recycling of packaging from French consumer households. Citeo Pro (launched Jan 2026) handles B2B packaging separately.
Verpact
The Dutch PRO for household packaging, formed from the merger of several Dutch packaging organisations. Based in the Netherlands.
Fostplus
Belgium's PRO for household packaging (B2C). Alongside Valipac (B2B), Fostplus manages packaging waste collection in Belgium.
ARA — Altstoff Recycling Austria
Austria's dominant PRO. Known for its gram-level fee precision and detailed material sub-category requirements.
CONAI
Italy's national packaging consortium. The umbrella body that oversees Italy's EPR system. Material-specific consortia (COMIECO for paper, COREPLA for plastics, etc.) operate under CONAI.
Ecoembes
Spain's PRO for household packaging (light containers and paper/cardboard). The main EPR body Spanish brands interact with.
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VE — Vollständigkeitserklärung
"Completeness declaration." Germany's annual declaration required for producers placing over 80,000 kg of packaging on the German market per year. Must be certified by an independent auditor.
SIREN/SIRET
French company registration numbers. Needed when registering with Citeo as a French entity. Non-French companies registering as foreign producers can use their home country registration number instead.
Authorised representative
A person or entity based in an EU member state appointed by a non-EU brand to fulfil EPR obligations on its behalf. Required in some countries (France, Germany for non-EU brands) as a formal legal mandate.
Material category
The classification used for EPR reporting and fee calculation: paper/cardboard, plastics, glass, steel, aluminium, wood, other. Fees vary by material; some countries use more granular subcategories (Belgium distinguishes 7+ plastic types from 2026).
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DoC — Declaration of Conformity
A formal written declaration required under PPWR Article 6 that packaging meets the regulation's recyclability and material requirements. Mandatory from 12 August 2026. Stored by the producer; not submitted to authorities unless requested.
Annex VIII documentation
The technical documentation file that must support your DoC. Contains evidence of recyclability design, material declarations, and compliance with PPWR Articles 5–9. Must be maintained for 10 years.
Recyclability grades (A–E)
A five-tier grading system for packaging recyclability to be established by EU Commission delegated acts by 1 January 2028. Grade A = most recyclable, Grade E = least recyclable. Grades will drive eco-modulation from 2030.
Eco-modulation
The adjustment of EPR fees based on packaging recyclability and recycled content. Recyclable packaging pays lower fees; non-recyclable or contaminating packaging pays higher fees. Currently applied by PROs based on national criteria; harmonised EU rules expected from 2028–2030.
Recycled content targets
PPWR Article 7 mandates minimum percentages of recycled plastic content in plastic packaging, effective from 1 January 2030. Targets range from 10% (contact-sensitive film) to 35% (single-use bottles), varying by packaging type.
Re-use targets
PPWR Article 29 requires e-commerce packaging to be 10% reusable (by number of units) by 2030, rising to 50% by 2040. DTC brands selling in the EU will need to demonstrate a compliant re-use offer by 2030.
PFAS
Per- and polyfluoroalkyl substances — a class of synthetic chemicals used in some food-contact packaging coatings for grease resistance. PPWR Article 5 bans PFAS in food-contact packaging from 12 August 2026. Applies to fast food containers, bakery boxes, microwave-safe packaging, and similar.
DRS — Deposit Return System
A system where consumers pay a deposit on beverage containers and receive it back when they return the container for recycling. PPWR Article 50 requires EU member states to establish DRS for plastic bottles and metal cans by 2029.
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Tonnage
EPR fees are calculated per tonne (1,000 kg) of packaging by material. Most reporting systems require you to know the total kg of each material type you've placed on the market per country per year.
Licensing / Lizenzierung
The German term for entering your packaging into a PRO's licensed system. When you sign a contract with a German PRO, you "license" your packaging volumes with them. This is distinct from LUCID registration — you do both.
Threshold
The minimum volume below which a country's full EPR fee obligations don't apply (though registration or declaration obligations often still do). Germany: 50 kg. Netherlands: 50,000 kg. Belgium: 300 kg. France, Italy, Austria: no threshold (registration required for all producers).
Advance payment / reconciliation
Most PROs require you to pay fees in advance based on estimated packaging volumes for the coming year, then reconcile with actual data at year-end. If you under-estimated, you pay the difference. If you over-estimated, you receive a credit.
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| Term | What it means in one sentence |
|------|-------------------------------|
| EPR | You (the brand) fund the recycling of your packaging |
| PPWR | The EU law replacing the old Packaging Directive (Aug 2026) |
| PRO | The body you pay EPR fees to in each country |
| LUCID | Germany's packaging register — get a number here first |
| DoC | Your written declaration that packaging is PPWR-compliant |
| Eco-modulation | Recyclable packaging = lower EPR fees |
| VE | Germany's annual completeness declaration (>80,000 kg) |
| Threshold | The volume below which full fees don't apply |
| PFAS ban | No fluorinated coatings in food-contact packaging from Aug 2026 |
| Re-use target | 10% of e-commerce packaging must be reusable by 2030 |
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Ready to go deeper? Read What is EPR and why does it affect your online store? to see how all these pieces fit together.