EPR in practice: who bears responsibility, how eco-modulation works, and what it costs

Reading time: 5 minutes | Category: Packaging Regulations | Last updated: June 2026

The acronym EPR is appearing with increasing frequency in industry — in questionnaires from customers, in supply chain audits, and in packaging solution proposals. From 12 August 2026, however, it is no longer just an ESG buzzword: the PPWR regulation (EU 2025/40) is launching a new mechanism that will directly affect the costs of every company placing packaging on the EU market. It is called fee eco-modulation, and its logic is straightforward — the less recyclable the packaging, the higher the rate.

This article answers three practical questions: who exactly bears the EPR obligation, how eco-modulation works in practice, and how to prepare for the change before your collective scheme invoice arrives.

What EPR is and why it is changing

EPR – Extended Producer Responsibility – is the principle whereby whoever places packaging on the market bears financial responsibility for managing that packaging at the end of its life. In doing so, the state shifts the costs of collecting, sorting, and recycling packaging waste from municipal waste management systems onto the companies that place packaging on the market.

EPR systems have been operating in the EU since the 1990s — in the Czech Republic as EKO-KOM, in Germany as the Duales System. The old model, however, had a systemic flaw: contributions were tied primarily to weight and material, not to the actual environmental impact of the packaging. A company manufacturing a multi-layer laminate that cannot in practice be recycled paid at a similar rate to a company using mono-material packaging that a sorting line can process without difficulty. The result was zero financial incentive for better design.

PPWR rewrites this system. It introduces mandatory eco-modulation of fees, harmonises rules across all Member States, and significantly tightens reporting requirements. The intent is clear: to ensure that the price of packaging reflects the true environmental cost of its disposal — and thereby motivate companies to switch to more easily recyclable or reusable solutions. The delegated act on EPR registration and reporting (Article 44(14) PPWR) was published in February 2026 and establishes the framework within which collective schemes across the EU will implement the new logic.

Who exactly bears the EPR obligation

This is where most confusion arises — transport packaging follows a different logic to sales or grouped packaging. PPWR in Article 3(1)(15) defines a producer as the economic operator who first places transport packaging or a packaged product on the market of a given EU Member State. In industrial practice, this covers the following situations:

1) You supply empty transport packaging (KTP boxes, transport crates, pallets, etc.) to a customer

The EPR obligation rests with your company as the supplier. For dimensionally stable transport packaging such as plastic crates or boxes, Article 3(1)(15)(a) PPWR provides that the producer is whoever first delivers them on the territory of a given Member State — meaning you as the supplier, not the customer who fills them and ships them onward. This is the key distinction compared to sales packaging: no EPR obligation arises for a customer who takes delivery of empty transport packaging.

2) You supply goods to a customer in transport packaging

The EPR obligation rests with your company, since you are the first to place the packaged product on the market in the given Member State.

3) You purchase and import empty packaging from a manufacturer outside the EU (for example, from Turkey or China)

As an EU importer established in an EU Member State, you are the producer within the meaning of PPWR. Article 3(1)(17) defines an importer as “any natural or legal person established in the Union who places on the market packaging from a third country” — and the importer is also the producer. You bear EPR obligations directly as the first entity in the supply chain. We recommend verifying that the foreign supplier holds the documentation required for your EPR reporting and addressing this contractually.

4) You import packaged goods from third countries

If you import products in packaging from overseas, EPR responsibility rests with you as the first entity placing goods on the EU market — not with the foreign manufacturer.

How eco-modulation works in practice

From approximately 2030, EPR fees will be directly derived from how easily the packaging can be recycled.

The Commission must adopt Design for Recycling (DfR) criteria by 1 January 2028. Member States will then have 18 months to introduce harmonised eco-modulated fees. Harmonised eco-modulation under PPWR thus becomes mandatory no earlier than summer 2029, in practice from 2030.

Each item of packaging will be assigned to a recyclability scale based on these DfR criteria. The mechanism works similarly to an energy label on household appliances.

Based on this assignment, a coefficient is set by which the base EPR fee rate is multiplied:

• Grade A (easily recyclable, ≥ 95% by weight): lower EPR fee, with a potential bonus for recycled content in some schemes;
• Grade B (moderately recyclable, ≥ 80% by weight): base rate;
• Grade C (≥ 70% by weight): higher rate; from 2038 banned from the market;
• Grades D and E (below 70% by weight): banned entirely from 2030, cannot be placed on the market.

The specific coefficients for individual grades will be set by Commission implementing acts — these have not yet been adopted. EPR contributions currently range in the order of hundreds of euros per tonne of material across various Member States. The difference between grade A and less recyclable packaging can be manifold. For a company placing tens of thousands of tonnes of packaging on the market annually, this runs to figures in the millions.

Add to this the administrative costs of registration in national EPR registries and regular reporting on the volumes and characteristics of packaging placed on the market. The total EPR compliance burden therefore consists of the fee itself and of investment in tracking and reporting systems. For industrial companies, this leads to one conclusion: packaging design is becoming a direct component of cost calculation.

Advantage of reusable packaging in the EPR system

Reusable packaging in a closed industrial loop has a structural advantage in the EPR system: packaging is reported to the system once upon first being placed on the market, not repeatedly with each use.

A KLT box or KTP container circulating between a plant and a customer fifty times generates an EPR fee once, whereas fifty single-use cardboard boxes generate it fifty times.

Practical impact: regular transport routes using single-use packaging are the best candidates for switching to a returnable solution. The EPR saving there will be greatest and most easily demonstrable. The switch simultaneously addresses other PPWR requirements: reuse targets and void space rules.

From an EPR reporting perspective, digital tracking of packaging also has direct practical value: it provides accurate data on cycle counts and the condition of each piece — precisely the type of documentation EPR systems require and which will, from approximately February 2029, be a condition for QR code labelling of reusable packaging.

What EPR obligations are not

A number of concerns circulate in the industry around EPR that are exaggerated or imprecise. Let us address them:

• EPR obligations do not apply to companies that merely receive empty transport packaging. A customer who takes delivery of empty KLT boxes from a supplier and fills them themselves does not pay the EPR fee for those boxes — the obligation rests with the supplier who first delivered them into the EU market.
• EPR obligations do not require certification of each piece of packaging. There is no “EPR certification”. There is producer registration in a national EPR scheme and regular reporting on packaging volumes.
• EPR obligations do not apply to packaging that a customer receives and returns. If you supply goods to a customer in packaging that is returned and continues to circulate in your loop, waste does not arise after each delivery and the EPR logic changes fundamentally.

EPR in the context of your customer relationships

Your customers may already be asking you about EPR. Procurement managers are receiving sustainability questionnaires from parent companies about supply chain practices. Certification audits include questions about the EPR status of packaging you were not even considering two years ago.

Specific questions we are seeing with increasing frequency:

• What is the recyclability grade of the packaging we purchase from you?
• Do you have data on cycle counts and packaging condition for EPR reporting purposes?
• Who bears EPR responsibility for packaging in our shared loop — you or us?
• Do you have recycled content documentation?

The right answer to these questions is specific, not general. State the recyclability grade, the proportion of reusable packaging, and how their circulation is tracked. Avoid responses such as “we’re working on it.” Customers want figures and documentation.

A supplier who answers these questions specifically — with a documented recyclability grade, data on packaging circulation, and clearly contractually defined EPR responsibility — is substantially more credible and valuable to a buyer than a supplier who simply offers packaging.

Eco-modulation thus creates a new type of commercial argument: “Our packaging or packaging solutions will reduce your EPR fees” is a specific statement with financial implications, not a vague ESG claim. And specific financial arguments work in purchasing committees.

If you do not currently have this data available, we recommend beginning to collect it in parallel with EPR registration preparation — not afterwards.

How to prepare: four practical steps

Selected PPWR provisions are enforceable from 12 August 2026. From mapping the situation to implementing changes, months typically elapse. Companies that only start after this date will be playing catch-up. These steps are the absolute minimum:

1. Packaging portfolio gap analysis. Review all packaging you place on the market. For each type, establish material composition, current recyclability assessment, and approximate annual volumes. Without this data, you cannot estimate the EPR burden or prioritise changes.
2. Verify EPR status throughout your supply chain. If you purchase transport packaging from manufacturers outside the EU — from Turkey, China, or other countries — verify that your EPR obligations as an importer are covered. As an EU importer, you are the producer and bear EPR responsibility directly. Also verify that your foreign supplier holds material composition and recyclability documentation that you will need for reporting.
3. Have a recyclability assessment carried out for key packaging. The result will tell you which grade the packaging falls into, and hence what EPR rate you can expect. If packaging falls into an unfavourable grade, you still have time to consider redesign or switching to a reusable alternative before eco-modulated rates come into effect.
4. Set up reporting processes. EPR reporting will be regular and data-intensive. It will cover packaging volumes, material, recyclability, and recycled content. If you do not currently have this data in any system, securing it should be your priority. For companies working with reusable transport packaging, a pool management system is the natural source of this data.

Overview of key obligations

Frequently asked questions