Germany vs United Kingdom EPR: Rules Compared
Last verified
Germany and United Kingdom both run packaging EPR, but the rules differ. Both require producers to register. United Kingdom asks for its first annual report earlier, on April 1 against May 15 in Germany. Every figure below links to its primary source.
Germany and United Kingdom side by side
2 of 9 rows have a verified figure on each side of Germany and United Kingdom; a cell reads “not yet published” when a side has none, and an exemption row reads “none recorded; see thresholds” when no exemption is on record.
| Measure | Germany | United Kingdom | Stricter |
|---|---|---|---|
| Registration duty | Required | Required | Same |
| Producer organisation | more than one producer responsibility organisation | producer compliance schemes | Not comparable |
| Lowest revenue exemption | none recorded; see thresholds | none recorded; see thresholds | Not comparable |
| Lowest weight exemption | none recorded; see thresholds | none recorded; see thresholds | Not comparable |
| First annual report date | May 15 | April 1 | United Kingdom |
| Published penalties | not yet published | not yet published | Not comparable |
| Report file | xml | csv | Not comparable |
| Paper fee, cheapest matched rate | not yet published | 196 GBP/tonne | Not comparable |
| Plastic fee, cheapest matched rate | not yet published | 423 GBP/tonne | Not comparable |
Both programmes require a producer to register, in Germany and in United Kingdom.
The earliest annual report date is May 15 in Germany and April 1 in United Kingdom, 44 days apart. United Kingdom leaves less time to prepare, so its data has to be ready first.
Who runs the programme in Germany and United Kingdom
Who collects and who the producer files with, in Germany and then United Kingdom.
| Aspect | Germany | United Kingdom |
|---|---|---|
| Regime | Packaging producer responsibility: register in LUCID, participate packaging subject to system participation in a dual system, and report volumes | Extended producer responsibility (EPR) for packaging, under the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 |
| Regulator | Zentrale Stelle Verpackungsregister (ZSVR), which runs the LUCID Packaging Register; competent state authorities enforce | Four environmental regulators (Environment Agency, Natural Resources Wales, SEPA, NIEA); PackUK is the scheme administrator that sets fees |
| Producers obligated | Yes | Yes |
| Registration | Required, LUCID Packaging Register (ZSVR) | Required, Report packaging data (RPD) service, run by Defra and the regulators |
| Producer organisation | more than one producer responsibility organisation; membership optional | producer compliance schemes; membership optional |
| Transfer of responsibility | Allowed | Not allowed |
| Revenue counted as | not yet published | worldwide revenue, GBP, previous accounting year |
| Who counts as the producer | other: manufacturer or brand owner, manufacturer, importer, first distributor, authorised representative; primary: manufacturer or brand owner, importer, first distributor, authorised representative; secondary: manufacturer or brand owner, importer, first distributor, authorised representative; service: manufacturer or brand owner, manufacturer, importer, first distributor, authorised representative; shipping: manufacturer or brand owner, packer and shipper, importer, first distributor, online marketplace seller, authorised representative; tertiary: manufacturer or brand owner, manufacturer, importer, first distributor, authorised representative | other: manufacturer, importer, online marketplace; primary: brand owner, packer and shipper, importer, online marketplace, seller; secondary: brand owner, packer and shipper, importer, online marketplace, seller; service: brand owner, packer and shipper, manufacturer, importer, seller; shipping: brand owner, packer and shipper, importer, online marketplace, seller; tertiary: brand owner, packer and shipper, importer, online marketplace, seller |
The two programmes are organised differently. Germany uses more than one producer responsibility organisation; United Kingdom uses producer compliance schemes. For a seller in both, that usually means two different counterparties, two different sign-up routes and two different sets of terms to read before the first report is due.
What Germany and United Kingdom cover, side by side
Each row below is one published feature of the two programmes; a cell reads “not yet published” when Germany or United Kingdom has no verified entry for it in the dataset.
| Aspect | Germany | United Kingdom |
|---|---|---|
| Materials covered | paper and card, glass, plastic, steel, aluminium, fibre based composite, other | aluminium, fibre based composite, glass, paper and card, plastic, steel, wood, other |
| Product classes covered | primary packaging, secondary packaging, shipment packaging, tertiary packaging, reusable packaging | primary packaging, secondary packaging, shipment packaging, tertiary packaging, reusable packaging |
| Sales channels addressed | retail, wholesale, online, online marketplace | retail, wholesale, online, online marketplace |
| Producer duty: primary packaging | manufacturer_brand_owner; importer; first_distributor; authorised_representative | brand_owner; packer_shipper; importer; marketplace; seller |
| Producer duty: secondary packaging | manufacturer_brand_owner; importer; first_distributor; authorised_representative | brand_owner; packer_shipper; importer; marketplace; seller |
| Producer duty: tertiary packaging | manufacturer_brand_owner; manufacturer; importer; first_distributor; authorised_representative | brand_owner; packer_shipper; importer; marketplace; seller |
| Producer duty: shipping packaging | manufacturer_brand_owner; packer_shipper; importer; first_distributor; online_marketplace_seller; authorised_representative | brand_owner; packer_shipper; importer; marketplace; seller |
| Producer duty: service packaging | manufacturer_brand_owner; manufacturer; importer; first_distributor; authorised_representative | brand_owner; packer_shipper; manufacturer; importer; seller |
| Producer duty: other packaging | manufacturer_brand_owner; manufacturer; importer; first_distributor; authorised_representative | manufacturer; importer; marketplace |
| Excluded from scope | not yet published | charities supplying or importing packaging |
| Reporting categories | not yet published | 8, material and packaging class |
| Published targets | not yet published | plastic_recycling_obligation 57 by 2026-12-31; plastic_recycling_obligation 59 by 2027-12-31; glass_recycling_obligation 76 by 2026-12-31; glass_recycling_obligation 78 by 2027-12-31; aluminium_recycling_obligation 62 by 2026-12-31; aluminium_recycling_obligation 63 by 2027-12-31; steel_recycling_obligation 81 by 2026-12-31; steel_recycling_obligation 82 by 2027-12-31; wood_recycling_obligation 46 by 2026-12-31; wood_recycling_obligation 47 by 2027-12-31; paper_board_fibre_composite_recycling_obligation 77 by 2026-12-31; paper_board_fibre_composite_recycling_obligation 79 by 2027-12-31 |
| Exemption 1 | not yet published | Charities that supply or import filled or unfilled packaging in the UK, excluding subsidiaries that trade for profit. |
Thresholds and exemptions in Germany and United Kingdom
Every verified threshold Germany and United Kingdom publish, as each states it.
| Place | Measure | Amount | Effect | Basis as published |
|---|---|---|---|---|
| Germany | packaging tonnage | 80 tonnes | declaration-of-completeness trigger | glass placed on the German market in the previous calendar year (reached or exceeded) |
| Germany | packaging tonnage | 50 tonnes | declaration-of-completeness trigger | paper, paperboard and cardboard in total, previous calendar year (reached or exceeded) |
| Germany | packaging tonnage | 30 tonnes | declaration-of-completeness trigger | ferrous metals, aluminium, plastics, beverage cartons and other composites in total, previous calendar year (reached or exceeded) |
| Germany | packaging tonnage | 10 tonnes | reduced duty | packaging subject to system participation made available for the first time in the previous calendar year |
| United Kingdom | packaging tonnage | 25 tonnes | registration trigger | packaging supplied or imported in the UK in the previous calendar year |
| United Kingdom | revenue | £1,000,000 | registration trigger | worldwide annual turnover |
| United Kingdom | packaging tonnage | 50 tonnes | reduced duty | with turnover above 1 million and up to 2 million pounds, an obligated producer is small; above 50 tonnes with turnover over 2 million pounds is large |
United Kingdom exemption: Charities that supply or import filled or unfilled packaging in the UK, excluding subsidiaries that trade for profit. It does not have to be applied for.
Read the basis column first: the same amount can exempt a producer in one programme and only simplify its report in another.
Fees per kilogram for shared materials
United Kingdom publishes per-kilogram rates in the dataset; Germany does not. Reason: Dual-system participation fees are set by each operator's contract and no public tariff has been retrieved; the fee engine asks for the customer's contracted rates instead of estimating. The rows therefore show United Kingdom only. Until both sides publish per-kilogram rates for the same material class, a fee comparison between Germany and United Kingdom would mean inventing a figure, and this page does not do that.
United Kingdom: the 2025-26 fee schedule of PackUK extended producer responsibility for packaging (base fees), effective June 27, 2025, is the source of the per-kilogram rates used on this page.
United Kingdom 2025-26: the category “Paper and card” is published at 196 GBP/tonne.
United Kingdom 2025-26: the category “Plastic” is published at 423 GBP/tonne.
United Kingdom 2025-26: the category “Glass” is published at 192 GBP/tonne.
Deadlines in Germany and United Kingdom
Each verified date, with the period it covers when one is given.
| Place | Kind | Date | Covers |
|---|---|---|---|
| Germany | report | June 1, 2027 | calendar year 2026 |
| Germany | report | December 31, 2026 | calendar year 2027 |
| Germany | report | May 15, 2027 | calendar year 2026 |
| United Kingdom | report | October 1, 2026 | the first half of 2026 |
| United Kingdom | report | April 1, 2027 | the second half of 2026 |
| United Kingdom | report | April 1, 2027 | 2026-P0 |
| United Kingdom | registration | October 1, 2026 | not yet published |
| United Kingdom | registration | April 1, 2027 | not yet published |
| United Kingdom | other | January 31, 2027 | calendar year 2026 |
The earliest annual report date is May 15 in Germany and April 1 in United Kingdom, 44 days apart. United Kingdom leaves less time to prepare, so its data has to be ready first.
Penalties in Germany and United Kingdom
What each side has published; a side without an amount says so.
Report formats in Germany and United Kingdom
How the report file for Germany compares with the one for United Kingdom.
| Aspect | Germany | United Kingdom |
|---|---|---|
| Layout | LUCID producer volume report (XML upload, section 10 VerpackG) XML interface 1.0, guide version 1.3 (12 August 2026), VerpackG material codes (reports 2019 to 2026) | UK EPR packaging data file (large and small producer) 2026 specification, GOV.UK page last updated 19 August 2026 |
| Recipient | Stiftung Zentrale Stelle Verpackungsregister (ZSVR), LUCID packaging register | The four UK environmental regulators through the Report packaging data (RPD) service |
| How it is submitted | LUCID XML upload. The customer signs in, uploads the file, checks the displayed data and confirms. | Report packaging data service on GOV.UK. The customer, as an approved person, uploads the CSV. A compliance scheme can do this on the producer's behalf. |
| File type | xml | csv |
| Encoding | utf-8-sig | utf-8 |
| Delimiter | not yet published | , |
| Decimal separator | , | . |
| Columns | 8 | 15 |
| Required columns | 8 of 8 | 6 of 15 |
| Weight unit | kg | kg |
| Period basis | calendar year | half year |
Germany report specification: XML producer volume report with elements VersionNoInterface, PackagingTypeCode, TypeOfReportCode, ReportingPeriodFrom, ReportingPeriodTo and one SystemOperator with its SystemOperatorID and a Material list (MaterialCode, Mass).
United Kingdom report specification: GOV.UK Report packaging data: create your reporting file, Table 1a (large producers) and Table 1b (small producers), with code tables 2 to 7
The two layouts differ in file shape as well as in columns, so a report built for Germany cannot be sent to United Kingdom unchanged. Each report is built from the same underlying measurements and exported separately.
Which to plan for first, Germany or United Kingdom
Plan around the earlier report date first. United Kingdom asks for its first annual report on April 1, before Germany, so its data has to be ready first.
Questions about comparing these two programmes
Is Germany or United Kingdom stricter on packaging EPR?
Both require producers to register. United Kingdom asks for its first annual report earlier, on April 1 against May 15 in Germany.
Do I register in both Germany and United Kingdom?
Germany requires producers to register. United Kingdom requires producers to register.
How do the fees per kilogram compare in Germany and United Kingdom?
The dataset does not hold per-kilogram rates for the same material class on both sides, so this page does not compare fees.
Which deadline comes first, Germany or United Kingdom?
The earliest annual report date is May 15 in Germany and April 1 in United Kingdom, 44 days apart. United Kingdom leaves less time to prepare, so its data has to be ready first.
How these figures are made
Sources
- verpackungsregister.org: system participation retrieved
Original wording: you must finance the recycling of your packaging by participating that packaging in a system.
Original wording: You can conclude your system participation agreement with the system operator of your choice.
Original wording: you are required to conclude a system participation agreement with a system operator.
- verpackungsregister.org: declaration of completeness retrieved
Original wording: The Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR) and the competent state authorities
Original wording: Glass: 80 tonnes
Original wording: Paper, paperboard, cardboard (PPC) in total: 50 tonnes
Original wording: Ferrous metals + aluminium + plastics + beverage cartons + other composites (lightweight packaging) in total: 30 tonnes
Original wording: by no later than 15 May of any given year for the previous year.
- verpackungsregister.org: find out about registrations retrieved
Original wording: If you are distributing packaged goods in Germany, you have to be registered with the LUCID Packaging Register.
Original wording: you must register with the LUCID Packaging Register. Registering is free of charge.
Original wording: There are two different packaging categories: packaging subject to system participation and packaging not subject to system participation.
- verpackungsregister.org: distinguishing between manufacturers producers retrieved
Original wording: A producer is every natural or legal person who, as a manufacturer, importer or distributor, makes a unit of packaging available for the first time
- verpackungsregister.org: data reporting retrieved
Original wording: A simplified reporting requirement applies to producers who made available less than 10 tonnes of packaging subject to system participation
Original wording: Year-end volume reports for the previous year (actual volumes) can only be filed up to 1 June.
Original wording: Initial planned volume reports for the following year can only be filed by 31 December of the current year.
- gov.uk (how to comply with packaging recycling obligations as a large producer) retrieved
Original wording: go to schedule 5 of the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 (as amended)
Original wording: A compliance scheme cannot pay your waste disposal fees for you.
Original wording: you must meet your recycling obligations, including submitting your certificate or statement of compliance, by 31 January 2027
Original wording: Packaging recycling targets 2025 to 2027
- gov.uk: epr for packaging what you must do as a small producer retrieved
Original wording: Each of the 4 nations of the United Kingdom has its own regulator. You’ll be reporting to and monitored by the regulator for your nation.
Original wording: the fee is: £1,303 if you register directly with your environmental regulator £696 if you register through a compliance scheme
Original wording: Compliance schemes are third parties that help organisations meet the EPR for packaging requirements.
Original wording: annual turnover of more than £1 million and supplies more than 25 tonnes and no more than 50 tonnes of packaging
- gov.uk: check if you must comply with epr for packaging 2 retrieved
Original wording: you supplied or imported more than 25 tonnes of packaging in the UK in the previous year
Original wording: you must get your annual turnover from the last accounts that were available before 7 April 2026.
Original wording: your annual turnover worldwide was £1 million or more
Original wording: Charities that supply or import filled or unfilled packaging in the UK are exempt from EPR for packaging requirements.
- legislation.gov.uk: 1 retrieved
Original wording: a brand owner; (ii) a packer/filler; (iii) an importer or first UK owner; (iv) a distributor; (v) an online marketplace operator;
- gov.uk (packaging data check reporting periods and submission deadlines) retrieved
Original wording: 1 January to 30 June 2026 1 October 2026
Original wording: 1 July to 31 December 2026 1 April 2027
Original wording: 1 January to 31 December 2026 1 April 2027
Original wording: you must register for EPR for packaging each year, and pay the applicable fees by 1 October.
Original wording: you must register for EPR for packaging each year, and pay a registration fee by 1 April.
- gov.uk: report packaging data create your reporting file retrieved
Original wording: Report the weight of the individual materials used in the packaging you have supplied. You must report each material type separately.
Original wording: Add a new row of data for each packaging activity and each type of packaging you need to report.
- gov.uk (2025) retrieved
Original wording: This document provides base fees for year 1 (2025 to 2026) of the Extended Producer Responsibility (EPR) for packaging scheme.
Original wording: Paper and card 196
Original wording: Plastic 423
Original wording: Glass 192
- verpackungsregister.org: Anleitung XML Datenmeldung EN retrieved
Original wording: Mass: packaging material mass in kg to the third decimal place without thousands separators (decimal place demarcated with comma).
The free plan is enough to start. We estimate and prepare; you sign and submit.