Extended Producer Responsibility in the EU: Preparing for 2026
Extended Producer Responsibility has been part of the European waste landscape for decades, and most companies placing products on the EU market already contribute to one scheme or another. What is changing now is the character of those obligations. Over the course of 2026, EPR is moving from a fragmented set of national arrangements towards a more harmonised, better enforced and financially consequential framework, with the cost of compliance increasingly tied to the way a product is designed and to the markets a company sells into. For businesses that have treated EPR as a routine annual filing, this is a meaningful shift, and one worth preparing for now rather than at the point of application. In this article, we set out what is changing across packaging and textiles, how registration and the producer obligation actually work across borders, what it costs, and the practical steps companies can take to be ready.
What Extended Producer Responsibility now means
EPR makes producers financially, and often operationally, responsible for what happens to their products once consumers have finished with them. It is well established for packaging, batteries and electronics, and it is now extending to textiles for the first time at EU level. The underlying principle has not changed. What has changed is the rigour with which it is applied, the degree of harmonisation across member states, and the increasingly direct link between the fees a producer pays and the choices made at the design stage.
Packaging: the Packaging and Packaging Waste Regulation applies from August 2026
The Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, entered into force on 11 February 2025 and applies from 12 August 2026, replacing the previous Packaging and Packaging Waste Directive. Because it is a regulation rather than a directive, it applies directly across all 27 member states without national transposition, which removes much of the variation producers have had to navigate until now.
For EPR, the Regulation harmonises the definition of the producer, requires registration in national producer registers (Article 44), and confirms the producer’s responsibility for financing the collection, sorting and recovery of packaging waste (Article 45). It also ties fees to recyclability through eco-modulation, and requires producers that are not established in a given member state to appoint an authorised representative for EPR there. The sections that follow set out what registration involves, who actually carries the obligation in a cross-border chain, and what it costs.
Registering as a producer, market by market
There is no single EU-wide register. Each member state operates its own national producer register, and a producer must register in every member state where it places packaging on the market, then report the volumes and types it places there each year. Germany’s register, LUCID, run by the Central Packaging Register, is the most developed example, and other national systems vary in maturity and in the level of detail they demand.
Two points follow from this. First, registration obligations multiply with geographic coverage rather than with volume, so a company present in eight markets has eight registrations to maintain even if the volumes in each are modest. Second, the obligation is now actively policed down the chain. Under the Regulation, distributors must check that a producer is registered before making its packaging available, and must not place non-compliant packaging on the market. A missing registration is therefore not only a direct exposure for the producer, but a reason for its own distributors to stop selling its goods.
Who counts as the producer: a worked example
The producer obligation is not held in one place by default. It is determined market by market, by whoever first makes the packaged product available in each country (Article 3(15)). The same company can be the producer in one member state and not in another, and only one party can be the producer for a given unit of packaging in a given market.
Consider a manufacturer established in Ireland that produces packaged goods and sells them to a distributor in the Netherlands, which in turn supplies retailers in Germany, France and Belgium.
For the Irish market, the manufacturer is the producer only for the goods it places on sale in Ireland. The goods it ships to the Dutch distributor are not made available on the Irish market, so they carry no Irish producer obligation for the manufacturer.
In the Netherlands, the distributor is the first to make those goods available, so the distributor becomes the producer there, registers in the Dutch producer register, and pays Dutch EPR fees.
When the distributor then supplies retailers in Germany, France and Belgium, it becomes the producer in each of those markets as well, because it is the first to place the goods on each national market. It must register in the German, French and Belgian registers, pay into each national scheme, and, because it is established only in the Netherlands, appoint an authorised representative for EPR in each of the other three member states. A single product line can therefore create producer obligations in four countries, held by one company, under four separate fee schedules and four sets of reporting.
The role can move further down the chain. If the distributor sells to a German wholesaler who is the first to place the goods on the German market, the wholesaler becomes the producer in Germany instead. Which party carries the obligation depends on how the supply chain is structured, which is why groups operating across several markets need to decide deliberately where the producer role sits rather than discover it after the fact. The same logic applies to direct and online sales. A company selling from one member state straight to consumers in another is the producer in the destination market, and a seller based outside the EU must appoint an authorised representative for EPR in every member state where it sells.
Textiles: the revised Waste Framework Directive brings EPR for the first time
The revised Waste Framework Directive was adopted in September 2025, published in the Official Journal on 26 September and entered into force on 16 October 2025. It introduces mandatory EPR for textiles, covering clothing, footwear and household textiles such as linen and curtains, with member states able to extend the scope to mattresses. Producers will be responsible for financing the collection, sorting and recycling of these products.
Member states have 20 months to transpose the Directive into national law, by mid-2027, and 30 months to have functioning EPR schemes in place, by 2028, with micro-enterprises given an additional year. Separate collection of textile waste has been required across the EU since 1 January 2025, so the collection infrastructure is already taking shape ahead of the funding obligations. Fees will be eco-modulated, and member states are expected to take account of fast and ultra-fast fashion practices when setting producer contributions. Because this is a directive, the detail will sit in national law, so producers will need to track each market in which they operate rather than rely on a single EU rulebook.
What it costs
EPR fees are charged per tonne of packaging placed on each national market, and they vary considerably between member states and materials. In 2025, aluminium packaging fees ranged from around €48 per tonne in Belgium to over €1,000 per tonne in Sweden, with France near €185 and the Netherlands near €300. A company selling the same product across several markets therefore faces several different bills for the same packaging, each set by a different national scheme.
Eco-modulation is what turns these fees into a design signal. Under PPWR, packaging is assigned a recyclability performance grade, and the better the grade the lower the fee. Mono-material formats that are straightforward to recycle sit at the favourable end, while multi-material laminates, composites, carbon-black plastics and other hard-to-sort formats attract higher charges and, from 2030, the risk of market restriction. Because fees are weight-based, reducing the weight of a pack lowers the bill directly, and using certified recycled content can earn a further reduction under several national schemes.
The direction of travel is upward. As recycling targets rise and treatment costs increase through to 2030, EPR fees across the EU are widely expected to climb, and some national schemes are introducing carbon-based components on top of the existing material charges. For textiles, fees are not yet live across the EU, but they will follow the same eco-modulated logic as national schemes come into operation, with France’s long-running Refashion scheme as the established model and a clear expectation that member states will weight fees against fast and ultra-fast fashion.
How to prepare
The 2026 changes reward preparation, and most of the groundwork is practical rather than legal. We would suggest working through the following in sequence.
- Map your portfolio and footprint. Identify every product and packaging type you place on the EU market and the member states where you first make each available, since the producer obligation and registration are determined market by market.
- Establish where the producer role sits in your supply chain for each market, confirm your registration obligations in each, and appoint an authorised representative for EPR where you are not established locally.
- Assess recyclability and design now, so you can anticipate where eco-modulated fees will fall and where a design change would reduce them.
- Structure your data and documentation for reporting, drawing where possible on the technical files you may already be building for PPWR conformity.
- For textile products, track national transposition through 2026 and 2027 and begin preparing the product data that eco-modulation will require, ahead of schemes going live.
How Jordisk can help
Much of what EPR now demands is data, and much of that does not sit with the obligated company. Accurate figures on materials, weights, recyclability and the markets a product reaches usually have to come from suppliers, customers and converters, and collecting them is often slower and harder than expected, particularly where supplier relationships were not built with this kind of reporting in mind. The companies that find August 2026 manageable will be the ones that started asking for this information early, rather than at the point of filing.
The most important step is establishing who carries the producer responsibility in each market. Because the obligation falls on whoever first makes a product available in a given member state, it is easy for everyone in a value chain to assume that someone else is on the hook, and for registrations and fees to fall through the gap as a result. Reaching a clear, shared view of where the obligation sits, market by market, protects both you and your partners, and it is the foundation everything else is built on.
At Jordisk we help you reach clarity on what is in scope and where the legal obligation sits through an impact assessment, and we stay with you through to operational integration, the point at which managing PPWR and EPR becomes part of how the business runs rather than an annual scramble. If you want to talk with one of the team to understand how we can help your company, drop us a line at hello@jordisk.com.
