Is there a minimum volume before EPR applies?

Not under EU law. Since 12 August 2026 Regulation (EU) 2025/40 applies directly and Article 45(1) sets no turnover or volume de minimis for the packaging EPR obligation. Below 10 tonnes a year Article 44(8) gives you simplified reporting, a reduced data set filed annually, not an exemption. The national figures still exist as administrative rules and readers still search for them: 100 kg a year in Malta, 300 kg a year in Belgium and Latvia, 300 kg together with CZK 25,000,000 of turnover in Czechia, and 10 tonnes together with EUR 1m of turnover in Ireland. Treat them as fee and reporting simplifications in national practice, not as a line below which the duty disappears. The Dutch 50,000 kg reporting threshold remains in force, and is expected to lapse only in 2027/2028 once the Netherlands stands up the PPWR's own harmonised producer register.

When must I register for EPR?

In most member states the duty attaches at or before your first sale, with no grace period. Six markets set a numeric clock instead: Denmark 14 days before your first sale, Slovenia within 30 days of starting, the Netherlands within six weeks, Czechia within 60 days, Austria within two months to contract with a collection system, and Latvia within three months of crossing 300 kg.

When is the annual EU packaging report due?

There is no single EU date. Twenty member states publish a day-precise annual deadline, and they range from 20 January in Croatia to 1 August in the Netherlands. The most common date is 31 March, shared by eight of the twenty.

Do I have to register for EPR before I start selling?

In most EU markets, yes in effect: the duty attaches at or before the first package and there is no grace period. Denmark goes further and requires you to be in the register 14 days before you first make packaging available. Only six markets give you a numeric window after starting, and the longest, Latvia's three months, is written to start once you cross 300 kg in a calendar year. Read that as a national administrative clock rather than a shield: since 12 August 2026 Article 45(1) of Regulation (EU) 2025/40 attaches the EPR obligation itself with no volume de minimis.

Do I need to register for EPR in every EU country I sell to?

If you place packaged products on a market, that market's national registration duty applies to you, and from 12 August 2026 Article 44(2) of Regulation (EU) 2025/40 makes the pattern explicit EU-wide: producers register in the national register of each member state where they first make packaging available. Which registers apply to you depends on your channels and volumes; a marketplace may carry part of the duty in some countries.

Does the PPWR replace national EPR registration?

No. Article 44(2) of Regulation (EU) 2025/40 obliges producers to register in the national register of each member state where they first make packaging available. The national registers, statutes and deadlines stay in place; the regulation adds a floor beneath them.

EPR Registration Deadlines

EPR Registration Deadlines in the EU: How Long Do You Have?

Registration clocks, volume thresholds and reporting deadlines, read out of the packaging statutes of all 27 member states

By Daniel Vaknine5 August 202610 min read

Six EU markets put a numeric clock on packaging-EPR registration, and they disagree by more than three months. Denmark requires registration 14 days BEFORE your first sale; Slovenia allows 30 days after; the Netherlands six weeks; Czechia 60 days; Austria two months (to contract with a collection system); Latvia three months after crossing 300 kg. Everywhere else, the duty attaches immediately, before the first package.

European Union flags flying in front of a building

Updated 19 August 2026: revised now that the PPWR (Regulation (EU) 2025/40) applies, since 12 August 2026, so the national volume thresholds below are administrative rules rather than exemptions from the EPR obligation.

The registration-clock spread is typical of a landscape that is far less uniform than most sellers expect. Below are the two things we found when we read all 27 national packaging statutes side by side: how long each country actually gives you to register, and how far apart the annual reporting dates have drifted.

Where do these numbers come from?

Coverage is the national packaging-EPR statutes of all 27 EU member states, reviewed as of 25 July 2026. The source is the compliance registry behind Gramta: one file per market, in which each fact carries the statute or instrument that sets it, a verbatim quote in the original language, and a link to the official text. The 2026 change was checked against the primary text of Regulation (EU) 2025/40 on EUR-Lex on 5 August 2026.

Every figure below comes from an entry marked verified against a primary source. Where a market's date is set only by a scheme contract or by guidance we could not trace to a published instrument, it is left out rather than estimated. The assembly and the comparison are ours; each underlying fact belongs to the statute cited next to it.

One counting rule matters for the deadline section. Several markets have two annual dates: one set by the producer responsibility organisation you contract with, and one set in law for the report to the authority. This report counts the authority date. Our EPR reporting deadlines guide counts the scheme dates, which are usually earlier and are the ones you diarise in practice.

How long does each country give you to register?

The table below lists the six clocks in one place, each with the statute that sets it.

Market	The clock	Statute
Denmark	Register 14 days before you first make packaging available	Emballagebekendtgørelsen (BEK 1146/2025), § 21
Slovenia	Report your details to the ministry within 30 days of starting the activity	Uredba o embalaži in odpadni embalaži, 14. člen (3)
Netherlands	Notify the minister within six weeks of the scheme becoming applicable to you	Besluit regeling voor uitgebreide producentenverantwoordelijkheid, Art. 4(1)
Czechia	Apply for entry in the Seznam osob within 60 days of the duty arising	Zákon č. 477/2001 Sb. o obalech, § 14(4)
Austria	Conclude a collection-system contract within two months of first placing household packaging	Verpackungsverordnung 2014, § 8(1)
Latvia	Register with the State Environmental Service within three months of exceeding 300 kg in a calendar year	MK noteikumi Nr. 983, 5. punkts

Denmark is the one that catches people out, because it runs backwards. The other five start counting from an event you can look up afterwards; Denmark's § 21 requires you to be in the register a fortnight before the first parcel moves, which means the decision to open the market has to happen before the sale, not after it.

Austria is worth a precision note too. Its two months is the deadline to conclude the collection-system participation contract, not to appear in a register. Master-data registration through edm.gv.at happens separately.

Latvia needs one as well. Its clock is written to start once you exceed 300 kg in a calendar year, which used to read as "below 300 kg, nothing to do". That reading no longer holds: since 12 August 2026 Article 45(1) of the PPWR attaches the EPR obligation with no volume de minimis, so the 300 kg figure is the trigger for the Latvian registration procedure rather than a floor under the duty itself.

How far apart are the annual deadlines?

Twenty EU markets publish a day-precise annual packaging-report deadline, and they fall on eleven different calendar dates, from 20 January (Croatia) to 1 August (Netherlands). Only eight of the twenty share the most common date, 31 March. A seller shipping across the EU is never more than a few weeks from someone's deadline.

The table below lists the sixteen of those twenty where the date is fixed by a statute or a published authority instrument rather than by scheme practice.

Date	Markets	Instrument
20 January	Croatia (reusable packaging)	Pravilnik NN 137/2023
31 January	Ireland	S.I. No. 282/2014, reg. 13 and 15
15 February	Czechia	Zákon č. 477/2001 Sb., § 15(1)(b)
28 February	Slovakia	Vyhláška MŽP SR č. 366/2015 Z. z., § 15(5)
15 March	Austria	Verpackungsverordnung 2014, § 13(1b)
31 March	Belgium, Estonia, Portugal, Slovenia, Spain, Sweden	six national instruments, listed in Sources
1 May	Latvia	MK noteikumi Nr. 983, 16. punkts
15 May	Germany (Declaration of Completeness)	Verpackungsgesetz, § 11(1)
31 May	Denmark (the statute says before 1 June)	Emballagebekendtgørelsen (BEK 1146/2025), § 27
30 June	Finland	Valtioneuvoston asetus 1029/2021, 19 §
1 August	Netherlands (report to the minister)	Besluit beheer verpakkingen 2014, Art. 8(1)

Two of the four not shown, Bulgaria and Greece, also fall on 31 March, which is how that date reaches eight. Their dates reach us through scheme guidance rather than a statute we could quote, so they sit outside the table.

Underneath all of this, Article 44(7) of the PPWR sets a common date of 1 June for the information in Annex IX Part B. It does not sweep the national dates away. It sits alongside them.

Common misconceptions about EPR registration deadlines

"There is one EU-wide deadline." There is not, for registration or for reporting. Twenty member states publish a day-precise annual reporting date and they fall on eleven different days of the calendar. The PPWR adds a common 1 June information date from 2026, but it sits alongside the national dates rather than replacing them.

"You can sort out registration after the first orders ship." In most markets the duty attaches at or before the first package, and in Denmark the register entry must exist 14 days before it. Registering late is not a formality being processed; in several statutes it is the condition for being on the market at all.

"Small sellers are exempt." No. This was already a bad bet: most EU markets had no volume threshold, and the few that existed were low, 100 kg a year in Malta, 300 kg in Belgium and Latvia, and a weight figure paired with a turnover ceiling in Czechia (300 kg and CZK 25,000,000) and Ireland (10 tonnes and EUR 1m), both legs required.

Since 12 August 2026 the PPWR closes the gap: Article 45(1) attaches extended producer responsibility with no de-minimis, and Article 44(2) requires registration in that member state. Article 44(8) instead gives a small producer a reduced data set: under 10 tonnes of packaging a year, you report Annex IX Part B point 2 annually by 1 June, rather than the full set. A member state may set a lower threshold for a given year, never a higher one.

Keep the national numbers in view, because they still shape the paperwork. Registers, forms and fee schedules are national, and several of these figures survive as reporting or fee simplifications inside a national scheme. The Netherlands is the clearest example: its 50,000 kg distance-seller reporting threshold remains in force, expected to lapse in 2027/2028 once the country stands up the PPWR's harmonised producer register. None of these national figures remove the underlying obligation, so a national relief is not something to rely on before you confirm its current status with the scheme itself.

"The PPWR replaces the national systems." Article 44(2) obliges producers to register in each member state's national register; the national statutes, registers and deadlines all stay. The regulation is a floor under the national systems, not a ceiling over them.

What does this mean for your store?

Three practical readings, none of them alarming.

First, registration is a per-market duty, and from 12 August 2026 Article 44(2) of the PPWR makes that explicit EU-wide: a producer registers in the national register of each member state where it first makes packaging available, and Article 44(4) makes registration a condition of placing packaging on that market at all.

Second, the clocks reward planning a market entry a few weeks ahead rather than reacting to the first order. Denmark's minus-14-days is the binding constraint in the set; if you plan to that, every other national clock is comfortable.

Third, the spread of deadlines is an argument for a single calendar rather than a single date. There is no quarter of the year in which nothing is due, and the 31 March cluster means eight filings can land in the same fortnight.

If you want the short version for your own store, the free EPR checker works out which markets you are obligated in from a few questions, and our guide to who must register for EPR covers the producer definition behind all of this. For the wider set of dates the regulation brings, see the PPWR timeline.

About Gramta

Gramta is an EPR and PPWR packaging compliance platform for EU sellers, built on the registry behind this article: one file per market, each fact carrying its statute and a verbatim quote from the official text, re-verified so you do not read 27 statutes twice a year.

The full per-country specifications, registration triggers, clocks, thresholds, reporting dates and the authorities behind them, are part of the product. Get started with Gramta to see them for the markets you sell into.

Sources:

Frequently asked questions

Is there a minimum volume before EPR applies?: Not under EU law. Since 12 August 2026 Regulation (EU) 2025/40 applies directly and Article 45(1) sets no turnover or volume de minimis for the packaging EPR obligation. Below 10 tonnes a year Article 44(8) gives you simplified reporting, a reduced data set filed annually, not an exemption. The national figures still exist as administrative rules and readers still search for them: 100 kg a year in Malta, 300 kg a year in Belgium and Latvia, 300 kg together with CZK 25,000,000 of turnover in Czechia, and 10 tonnes together with EUR 1m of turnover in Ireland. Treat them as fee and reporting simplifications in national practice, not as a line below which the duty disappears. The Dutch 50,000 kg reporting threshold remains in force, and is expected to lapse only in 2027/2028 once the Netherlands stands up the PPWR's own harmonised producer register.
When must I register for EPR?: In most member states the duty attaches at or before your first sale, with no grace period. Six markets set a numeric clock instead: Denmark 14 days before your first sale, Slovenia within 30 days of starting, the Netherlands within six weeks, Czechia within 60 days, Austria within two months to contract with a collection system, and Latvia within three months of crossing 300 kg.
When is the annual EU packaging report due?: There is no single EU date. Twenty member states publish a day-precise annual deadline, and they range from 20 January in Croatia to 1 August in the Netherlands. The most common date is 31 March, shared by eight of the twenty.
Do I have to register for EPR before I start selling?: In most EU markets, yes in effect: the duty attaches at or before the first package and there is no grace period. Denmark goes further and requires you to be in the register 14 days before you first make packaging available. Only six markets give you a numeric window after starting, and the longest, Latvia's three months, is written to start once you cross 300 kg in a calendar year. Read that as a national administrative clock rather than a shield: since 12 August 2026 Article 45(1) of Regulation (EU) 2025/40 attaches the EPR obligation itself with no volume de minimis.
Do I need to register for EPR in every EU country I sell to?: If you place packaged products on a market, that market's national registration duty applies to you, and from 12 August 2026 Article 44(2) of Regulation (EU) 2025/40 makes the pattern explicit EU-wide: producers register in the national register of each member state where they first make packaging available. Which registers apply to you depends on your channels and volumes; a marketplace may carry part of the duty in some countries.
Does the PPWR replace national EPR registration?: No. Article 44(2) of Regulation (EU) 2025/40 obliges producers to register in the national register of each member state where they first make packaging available. The national registers, statutes and deadlines stay in place; the regulation adds a floor beneath them.

Reviewed 19 August 2026 by Anton Kröger