Quick Answer
If you ship packaged goods to customers in the EU, you're subject to Extended Producer Responsibility (EPR) for packaging. You must register with a Producer Responsibility Organisation (PRO) in each country where you sell and pay license fees based on the weight and material of your packaging. Some merchants choose to pass these costs through to customers as a visible fee. Magical Fees lets you add a packaging EPR fee as a separate line item at checkout — by country, by product, automatically.
What You Need to Know About EU Packaging EPR
The EU Packaging and Packaging Waste Directive requires every member state to run an EPR program for packaging. If you place packaged goods on any EU market — including selling online from outside the EU — you're responsible for contributing to the collection and recycling of that packaging.
How it works
You register with a PRO in each country where you sell. The PRO manages collection and recycling infrastructure. You pay a license fee based on the weight and material type of the packaging you place on that market. Many national PROs are coordinated under the PRO Europe / Green Dot (Der Grüne Punkt) system.
Typical fee ranges by material
Fees vary significantly by country, but here are representative EU-wide ranges:
- Plastic packaging — €271–€1,955+/tonne (non-recyclable plastics can reach €3,909/tonne in some countries)
- Paper/Cardboard — €150–€190/tonne
- Glass — €96–€102/tonne
- Metal — €48–€480/tonne
- Composite/Beverage cartons — €818–€1,080/tonne
Eco-modulation is increasingly common — recyclable packaging gets lower rates, hard-to-recycle packaging gets penalized.
Who's affected
Any business that places packaged goods on an EU market, including:
- EU-based manufacturers and retailers
- Non-EU online sellers shipping to EU customers
- Marketplaces listing products from third-party sellers (many EU countries now require marketplace compliance verification)
For detailed country-by-country rates, see PRO Europe's license fee page.
Should You Pass the EPR Fee Through to Customers?
This is a business decision, not a legal requirement. The EPR fee is your obligation as a producer — you're not legally required to show it as a separate charge to customers. Many businesses absorb it into product pricing.
But some merchants prefer transparency — especially when selling in multiple EU countries where packaging costs differ. Showing a "Packaging Recycling Fee" line item can:
- Explain why prices differ by destination country
- Demonstrate environmental responsibility
- Keep your base product prices consistent across markets
If you choose to pass it through, here's how.
How to Set Up EU Packaging EPR Fees With Magical Fees
Magical Fees handles the per-country, per-product logic.
1. Calculate your per-product packaging cost
Work out the packaging weight per product (or per product category) and multiply by the per-tonne rate for each target country. For example:
- A product shipped in 200g of cardboard packaging to Germany at €175/tonne = €0.035 per unit
- A product shipped in 50g of plastic packaging to France at €400/tonne = €0.020 per unit
If your products use similar packaging, you can simplify by grouping them into collections with the same fee.
2. Create fee rules by country
In Magical Fees, create a fixed-price fee for each country where you sell. Name it clearly — "EU Packaging Recycling Fee" or "Emballage Fee (France)."
Set the amount to your calculated per-unit packaging cost for that country. Target the rule to the relevant products or collections.
3. Add country location conditions
Add a location condition to each rule so it only applies to orders shipping to the correct EU country. Your German rule fires on German orders. Your French rule fires on French orders.
4. Group where rates are similar
If your packaging costs are similar across several EU countries, you can create a single rule covering multiple countries rather than one per country. Just add multiple countries to the location condition.
5. Test across markets
Place test orders shipping to different EU countries. Verify the fee appears as a separate line item with the correct amount, and doesn't show up for non-EU destinations.
Common Questions
Do you need to register with a PRO even if you're outside the EU?
Yes. If you sell packaged goods to EU customers, you need to register with the PRO in each destination country — even if your business is based outside the EU. Many countries allow you to appoint an authorized representative to handle registration.
What happens if you don't comply?
Fines, sales bans, and enforcement from national environmental authorities. Many EU countries now require online marketplaces to verify packaging EPR compliance before listing products from third-party sellers.
Do you need to display the Green Dot logo?
Not necessarily. The Green Dot (Der Grüne Punkt) is a trademark indicating participation in a PRO system. Its use varies by country — in some countries it's required on packaging, in others it's optional. Check with your national PRO.
How often do rates change?
PROs typically update their fee schedules annually. Rates tend to increase as eco-modulation incentives push recyclable packaging lower and non-recyclable packaging higher.
Further Reading
Always label deposits separately for compliance
Display bottle deposit fees as a clearly labeled, separate line item at checkout and on receipts. This meets regulatory transparency requirements, builds customer trust by showing exactly what they're paying, and makes it significantly easier to track deposits for reporting and audits. Use a clear label like "Bottle deposit" or "Container deposit (CRV)" so customers immediately understand the charge.
“Magical Fees is the only fee app that allows you to apply a fee based on a specific or individual state/province situation. All the other apps we tested only allow 'Location' (the entire country) which is a major limitation. The solution Magical Fees applies during the Cart to Checkout process is very smart and not a hassle. Very easy app to setup and the support was great.”