Brands often ask "how much will EPR cost us?" The honest answer is: it depends on what your packaging is made of, how much you ship to each country, and how recyclable your packaging is. But it's not complicated once you understand the structure.
Here's how the fee calculation actually works.
Every EPR system uses the same underlying logic:
EPR fee = weight (kg) × rate per kg × eco-modulation adjustment
You report kilograms of packaging per material per country. The PRO applies a rate per kg for each material. That rate is then adjusted up or down based on your packaging's recyclability characteristics.
The complexity comes from three variables:
The lowest-cost material category in most markets. Paper and cardboard packaging is well-integrated into existing recycling infrastructure, so PROs can fund collection at lower rates.
| Country | Indicative rate (per tonne) | Notes |
|---------|----------------------------|-------|
| Germany | €60–€100 | Varies by PRO; corrugated vs. coated board differ |
| France | €110–€160 | Citeo rates; eco-modulation applies |
| Netherlands | €80–€120 | Verpact rates |
| Italy | €80–€130 | COMIECO (paper consortium under CONAI) |
| Spain | €70–€110 | Ecoembes rates |
| Belgium | €95–€140 | Fostplus 2026 rates |
| Austria | €100–€150 | ARA rates; gram-level precision required |
For a typical e-commerce brand shipping 2,000 kg of cardboard boxes to Germany annually: €60–€100 × 2 tonnes = €120–€200/year.
Plastics carry the highest EPR rates because plastic recycling infrastructure is more expensive to operate and plastic packaging has a higher environmental impact per kg.
| Country | Indicative rate (per tonne) | Notes |
|---------|----------------------------|-------|
| Germany | €120–€250 | Rigid and flexible plastics differ significantly |
| France | €200–€400 | Wide range due to eco-modulation |
| Netherlands | €150–€250 | Below-threshold brands unaffected |
| Italy | €150–€300 | COREPLA handles plastics |
| Spain | €140–€250 | Ecoembes |
| Belgium | €210–€380 | Rising sharply post-2024; 7 sub-categories from 2026 |
| Austria | €200–€350 | ARA sub-categories: PE, PP, PET, etc. |
The spread within "plastics" is wide because not all plastics are created equal. From 2026 (Belgium) and progressively across all EU markets, plastic packaging must be reported by polymer type, not just as "plastic":
If your mailer is a poly mailer (LDPE), expect the highest plastic rate. If you're using PET bottles or HDPE containers, expect lower rates.
Glass is heavy but fully recyclable. EPR rates are low because glass recycling is well-established.
| Country | Indicative rate (per tonne) |
|---------|-----------------------------|
| Germany | €10–€25 |
| France | €15–€30 |
| Netherlands | €8–€18 |
| Italy | €5–€15 |
| Spain | €8–€20 |
| Belgium | €12–€25 |
| Austria | €5–€20 |
Glass is rarely a meaningful EPR cost for most DTC brands. The exception: wine, spirits, or premium beauty brands shipping heavy glass volumes.
Both are well-recycled. Steel is the cheaper of the two.
| Country | Steel rate (per tonne) | Aluminium rate (per tonne) |
|---------|----------------------|--------------------------|
| Germany | €30–€60 | €60–€100 |
| France | €60–€90 | €90–€130 |
| Netherlands | €40–€70 | €70–€110 |
| Belgium | €55–€75 | €85–€110 |
| Austria | €50–€80 | €90–€130 |
Aluminium commands a higher rate per tonne than steel despite both being recyclable, because aluminium cans are more valuable and the collection system is more premium.
Once the base rate is applied, PROs adjust fees based on eco-modulation criteria. These vary by country and PRO, but the general structure is:
Surcharges apply for:
Discounts apply for:
The magnitude of eco-modulation ranges from -50% (deep discount for highly recyclable packaging) to +100% or more (surcharge for non-recyclable or contaminating formats).
Under the PPWR, eco-modulation will be harmonised across the EU once recyclability grades A–E are adopted (expected 2028). Grade A packaging will carry a significant discount; Grade E packaging will face a surcharge.
Most PROs use flat per-tonne rates regardless of volume. There are no quantity breaks like commercial contracts — EPR is a regulatory fee, not a commercial transaction.
However, the reconciliation mechanism means you pay based on actual volumes, not estimates. If your shipments to Germany grow 40% year-over-year, your EPR fee grows 40% accordingly. Plan for this in your unit economics.
Scenario: A UK supplement brand selling into 3 EU markets (Germany, France, Italy). Per-order packaging:
Annual orders shipped: 5,000 to Germany, 3,000 to France, 2,000 to Italy
Step 1: Calculate kg per material per country
| Country | Orders | HDPE (kg) | Cardboard (kg) | Paper (kg) |
|---------|--------|-----------|----------------|-----------|
| Germany | 5,000 | 400 | 1,250 | 150 |
| France | 3,000 | 240 | 750 | 90 |
| Italy | 2,000 | 160 | 500 | 60 |
Step 2: Apply rates (using midpoint estimates)
Germany:
France:
Italy:
Total across 3 markets: ~€463/year
For a brand doing 10,000 EU orders per year, EPR fees are typically in the €300–€800 range. They scale with volume, but remain a small fraction of revenue (typically 0.1–0.5% of GMV for most DTC product categories).
For a detailed look at how packaging design changes translate into fee savings, see our expert article on packaging redesign for EPR savings.
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Next: Eco-modulation explained: how packaging design affects what you pay