Germany and France get most of the attention. But if you're selling across the Benelux and Austria, you also have EPR obligations in three more markets — each with its own system.
Here's what you need to know, fast.
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The Netherlands runs a producer responsibility system for household packaging through a collective PRO scheme. Since January 2023, the main PRO is Verpact — formed from the merger of Nedvang and several other organisations.
Brands placing more than 50,000 kg of packaging on the Dutch market per year must join the collective scheme and pay fees. Below that threshold, you're not required to pay into the collective scheme — but you're still required to register and keep records.
In practice, most DTC brands are well below 50,000 kg annually unless they're doing very large Dutch volumes. A brand shipping 100,000 orders/year with 300g of packaging per order places 30,000 kg — just under threshold.
However: the below-threshold rules changed in 2024. Even small producers must now submit a simplified annual declaration to demonstrate they're monitoring their packaging volumes.
The PRO landscape in the Netherlands is undergoing further consolidation. Verpact, Citeo (FR), and Fostplus (BE) formed a strategic alliance in October 2025 to align data standards and reduce administrative burden for cross-border producers. Practically, this means data you report to one may increasingly be compatible with the others — watch for harmonisation of declaration formats.
Dutch fees are among the lower rates in Western Europe. Paper/cardboard: approximately €80–€120/tonne. Plastics: €150–€250/tonne. Glass and metals are modest.
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Belgium has two EPR schemes for packaging:
Fostplus — household packaging (packaging that reaches consumers and enters the household recycling system). This is what most DTC brands need.
Valipac — industrial and B2B packaging (pallets, stretch wrap, transit packaging). Only relevant if you also wholesale to Belgian businesses.
If you place household packaging on the Belgian market — regardless of volume — you must declare to Fostplus. There is a simplified track for brands placing less than 300 kg per year (very low threshold), but the declaration requirement exists for everyone.
Brands above 300 kg/year pay standard Fostplus fees. Below 300 kg, a flat minimum fee applies.
For non-Belgian companies, registration as a "foreign producer" is available directly through Fostplus. You don't need a Belgian legal entity.
Belgium increased its plastic packaging fee rates from August 2024, with a further increase effective August 2026 under PPWR alignment. The 2026 rate increase includes 7 new material sub-categories for plastics — meaning you need more granular material data than "plastic" to correctly report from August 2026.
Fostplus is part of the October 2025 PRO alliance with Verpact (NL) and Citeo (FR/LU). Cross-border data alignment is in progress.
| Material | Approximate rate per tonne |
|----------|---------------------------|
| Paper / cardboard | €95–€140 |
| Plastics (contact-sensitive) | €290–€380 |
| Plastics (non-contact) | €210–€280 |
| Glass | €12–€25 |
| Steel | €55–€75 |
| Aluminium | €85–€110 |
Belgium's 2026 rates for plastic are notably higher than 2024 rates — factor this into your fee forecasts if Belgium is a significant market for you.
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Austria runs its EPR system through ARA (Altstoff Recycling Austria). ARA is the dominant PRO and covers the vast majority of packaging placed on the Austrian market.
Austria is notable for its gram-level fee precision — fees are calculated per gram of packaging per material, not per tonne rounded. This makes Austrian reporting more granular than most other markets and means you need accurate per-SKU packaging weights.
No de minimis threshold. If you place packaging on the Austrian consumer market, you must register and comply with ARA requirements.
Non-Austrian companies can register directly with ARA as foreign producers. You do not need an Austrian entity.
ARA's gram-level reporting is the most demanding of the 7-market set. You need to know, for each SKU:
If you don't have this data from your packaging supplier, ARA provides average weight tables for common packaging formats that you can use as an approved estimate.
ARA is aligning with PPWR requirements, which means recyclability assessments will become a component of fee calculation as the EU Commission adopts recyclability grade delegated acts (expected 2028). Until then, ARA's existing eco-modulation rules apply.
Austrian fees tend to be slightly higher than Netherlands but lower than Belgium for most materials. Paper/cardboard: €100–€150/tonne. Plastics: €200–€350/tonne. Glass is very low (€5–€20/tonne).
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| | Netherlands | Belgium | Austria |
|--|--|--|--|
| PRO | Verpact | Fostplus (B2C) + Valipac (B2B) | ARA |
| Threshold | 50,000 kg (fees); declaration for all | 300 kg (standard fees); declaration for all | No threshold — all producers |
| Reporting granularity | Material + weight | Material + weight + subcategory (from 2026) | Gram-level per material subtype |
| Foreign registration | Yes, direct | Yes, direct | Yes, direct |
| Key change 2026 | PRO alliance (NL/BE/FR/LU) | 7 new plastic sub-categories + higher rates | PPWR alignment in progress |
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For a deeper look at how fees are calculated across all 7 markets, read EPR fee comparison: Germany vs France vs Netherlands 2026 rates.