A jar of pasta sauce has usually passed through three companies before it reaches a shelf. One makes the glass and the film, one fills and seals it, one sells it. The name on the front belongs to none of them.
That name is what the EU rules read first, which is why the paperwork lands on the brand and not on the factory. This page compares the EPR software consumer brands use to hold their packaging data and report from it.
Your name on the pack decides who carries the duty
Extended producer responsibility and the EU packaging rules both work off the same question, which is whose product this is. Not who ran the filling line.
What the regulation actually says
The Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, defines the manufacturer in Article 3(13). The first limb is the obvious one, whoever physically makes the packaging.
The second limb is the one that matters to a brand owner. Where a company has packaging "designed or manufactured under its own name or trademark", that company is the manufacturer.
You can outsource every part of making the pack and still be the party the regulation is written about.

So the duties in Article 15 are yours. Ensure the packaging conforms, build the technical documentation file, draw up and sign the EU Declaration of Conformity, keep it for 5 years for single-use packaging or 10 for reusable, and make sure your name and address are on the pack or reachable from a QR code on it.
A second trademark on the pack changes nothing
Licensing deals and co-branded packs make people hope the duty is shared. The regulation closes that door in the same sentence.
Article 3(13)(a) applies "regardless of whether any other trademark is visible on the packaging or on the packaged product". Your co-packer's mark, a licensor's mark, a retailer's loyalty logo, none of it moves the duty off you.
That wording is worth knowing before a supplier tells you their name on the base means they will handle it.
One narrow escape for micro-enterprises
There is exactly one relief, in Article 3(13)(b), and both halves of it have to be true.
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You are a micro-enterprise. Fewer than 10 people, and turnover or balance sheet total under 2 million euro, measured against Commission Recommendation 2003/361/EC as it stood on 11 February 2025.
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Your packaging supplier is in the same member state as you. A Danish brand with a Danish supplier qualifies. The same brand buying film from Poland does not.
Where both are true, the supplier is the legal manufacturer and the declaration duty sits with them. It is a real lift for the smallest brands, and it disappears the moment you hire your tenth person or source across a border.
The packaging data you report sits with your co-packer
Being the responsible party is the easy half. The hard half is that the numbers a report wants are physical facts about an object made in someone else's building.
What a report actually asks for
No register accepts "one jar of sauce". Each one wants the pack broken into pieces, and each one wants it in its own shape.
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Every component separately. The jar, the lid, the liner in the lid, the front label, the back label, the shrink band, the tray, the case, the stretch wrap.
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The material of each component, at the level of detail the market uses, which can mean polymer type rather than just "plastic".
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The weight of each component in grams, not the weight of the filled product.
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How many you placed on that market in the reporting period, which is a sales figure, not a production figure.
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A recycled content share where the market modulates on it, per component.
Your finance system has the volumes. Your co-packer has everything else, usually in a specification sheet that was written for the production line rather than for a regulator.
A supplier swap is a paperwork event
Article 15 puts a series-production duty on the manufacturer. If a change in materials, design, supplier or process affects conformity, the technical documentation and the declaration have to be updated.
Co-packers change things. They re-source a film, switch a cap moulder, thin a label to save cost, and none of that reaches your compliance folder unless someone tells you.
For a brand this is the single biggest argument for holding the pack specification yourself rather than requesting it once a year. A spec you own can be versioned. An email attachment cannot.
Retail own-label runs the other way
If you make products that a retailer sells under the retailer's own brand, the same clause points at them, not you. Their name is on the pack, so they are the manufacturer.
You will still feel it, because they need the component data to do their job and they will ask you for it, often in their template and on their deadline. Brands that do both, their own labels plus own-label for a retailer, end up on both sides of the same request.
Every pack will need a recyclability grade
This is the change that moves packaging compliance out of the finance calendar and into the design studio, and it is the reason a brand needs its pack data structured rather than filed.
Grades of A, B or C, assessed by you
Article 6 says all packaging placed on the market has to be recyclable, and Article 6(3) puts the assessment on the manufacturer. The result is expressed as a recyclability performance grade of A, B or C.
Two thresholds follow. From 1 January 2030, or 24 months after the delegated acts land if that is later, packaging cannot go on the market below grade C. From 1 January 2038 it has to be grade A or B.
The detailed criteria per packaging category come from delegated acts the Commission is due to adopt by 1 January 2028, so the exact test is not published yet. The direction is fixed, the fine print is not.
The grade then moves the fee
Fee modulation already exists market by market, in various shapes. Article 6(8) makes it harmonised and mandatory, 18 months after those same delegated acts take effect, and ties it to the grade.
So the recyclability grade of a pack stops being a sustainability score and starts being a line in your cost of goods. A shrink sleeve that drops a bottle a grade shows up on an invoice, in every market you sell that bottle in.
Grades are also evidence. Article 6(9) says conformity with the recyclability requirements is demonstrated in the Annex VII technical documentation, which is the same file behind your declaration.
A sorting label is coming to your artwork
Article 12 adds a harmonised label showing material composition so consumers can sort the pack. It applies from 12 August 2028, or 24 months after the relevant implementing acts if that is later, and it is built from pictograms.
Transport packaging and deposit-return packaging are outside it. E-commerce packaging is explicitly inside it, so a mailer counts.
For most companies a label rule is a compliance task. For a brand it is an artwork change across every SKU, with print runs, retailer listings and photography behind it, which is why the pack data and the label decision want to live in the same place.
Where each tool gets your packaging data
Tools for brand owners differ less on reporting than on this one question, so it is worth settling before you compare features. The arc below places each tool between entering the data yourself and having someone collect it from your suppliers.

Repax sits at the left-hand end, and that is an honest limitation as much as a design choice. We give you the structure to hold a pack specification and keep it current. We do not phone your co-packer.
If your component data genuinely does not exist anywhere yet, the tools on the right are doing something we do not, and Assent and Ecoveritas are the two that have built the most around it.
What we looked for in EPR software for consumer brands
We only ranked tools whose own sites describe holding packaging data at SKU or component level for a company that brands packaging it did not make. That cut most of the EPR software market, because much of it is built to buy registrations for cross-border sellers instead.
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Does it hold a pack as components rather than as a single material total.
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Can it version a spec when a co-packer changes something mid-year.
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Does it do anything about recyclability, given the grade will drive the fee.
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Does it reach the declaration as well as the report, since both come off the same spec.
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How does the data arrive, whether you type it, sync it, or they chase suppliers for it.
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Which markets it covers, because brands rarely sell in one.
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Is the price knowable before a sales call.
The best EPR software for consumer brands ranked
Six tools cleared that bar. They solve genuinely different parts of the same problem, so the order runs from owning the pack data to having the work taken off your desk.
1. Repax
Repax is a product-data platform built on the idea that a pack is a structure, not a number. You describe it once and every report is generated from that description.

The spec has four reusable layers, product, assembly, component and material. Their own worked example is a wine bottle holding glass at 350g, a cork at 12g, an aluminium cap at 3g and a paper label at 7g.
That shape is why it suits a brand. It is the pack's bill of materials, so a co-packer's specification sheet maps onto it directly, and swapping one component updates every market report that uses it.
Reports come out in each market's own shape, with Denmark, Germany, France and Italy named on the product page, each with its own packaging category, material type, eco-modulation and typology fields.
Try Repax Core for free - no card required Describe your products once and Core builds the report each market and scheme expects. Try it free
One detail matters more for brands than for anyone else. Each shipped order locks in the spec at the point of sale, so reformulating a pack in June does not quietly rewrite what you placed on the market in March.
Data comes in from Shopify, WooCommerce, PrestaShop, Magento, CSV and Excel files, a REST API, and the Dinero and e-conomic accounting systems.
Two products are live. Core is the data layer and reporting engine above. Declare produces the signed EU Declaration of Conformity off the same specification, with Annex VIII fields enforced, an evidence vault linking each claim to its document, a frozen PDF with version history and a QR code pointing at a public verification page. A third product, Comply, registers you and files for you across EU markets, as a separate membership, so nothing here depends on it.
Repax is also our own product, which is why it leads the list, and the arc above shows the axis where rivals beat us.
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Best for brands that want to own the pack specification and produce both the report and the declaration from it.
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What it does for a brand owner holds each pack as components and materials, versions it, generates per-market reports, and generates the signed declaration.
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Who gets the packaging data you do, by API, file or connector, with the spec frozen per shipped order.
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Markets and streams Europe wide and multi-stream, covering packaging, electronics, batteries, textiles, fishing gear and single-use plastics.
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Pricing public and listed per tier, a free tier at 0 euro a month, Growth at 29 euro and Pro at 59 euro, with custom enterprise pricing, all excluding VAT as of July 2026.
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Watch-out Core prepares the filing and does not submit it, so the last click into each register is yours unless you add Comply. No PIM or PLM connector is named, and Declare covers packaging conformity only.
If you would rather someone else pressed submit, that is a real reason to look further down this list.
2. Recyda
Recyda comes at the same data from the design end, which makes it the closest thing here to a tool for a packaging developer.

Their platform scores a pack for recyclability against a long list of published frameworks, including RecyClass, CEFLEX, KIDV, the German ZSVR minimum standard, the APR Design Guide, COTREP and EN 18120. The UK Recyclability Assessment Methodology is supported by name.
Given where Article 6 is heading, that is the deepest published answer on this list to the grade question.
They also reach the declaration. Their PPWR product publishes a full status flow from pending review through technical documentation approved, declaration issued and declaration signed, with bulk export of declarations and Annex VII summaries and an audit log on every status change.
The limits are equally clear. Recyda is packaging only, no other waste stream is named anywhere, and their EPR flow ends at export rather than submission. They are also demo-only on price, and their platform is pitched as enterprise-grade for global brands.
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Best for brands whose packaging changes often and who want recyclability and the declaration handled where the pack is designed.
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What it does for a brand owner scores recyclability against the published frameworks, calculates EPR fees by country rule, and produces declarations plus Annex VII summaries.
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Who gets the packaging data you upload it, then they score and structure it.
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Markets and streams 20 or more countries by their own count, packaging only, with EPR markets named for the UK, Denmark, Italy, the Netherlands and France.
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Pricing no public price, demo first.
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Watch-out they export the report rather than filing it, and a brand with electronics or batteries in range will need a second tool. Our Repax and Recyda comparison goes through the overlap in detail.
3. Ecoveritas
Ecoveritas is the option to look at when the problem is scale, both the number of SKUs and the number of suppliers who have to answer for them.

They have been doing packaging data since 1999, and their own live figures give a sense of the shape of the work, more than 100 clients, over 4 million SKUs, more than 32,000 supplier data requests a year and over 250 annual returns.
Their stated country coverage is 80 or more, which is their claim rather than ours, and the same site describes deeper regulatory detail for a smaller set.
The distinctive thing is structural. In their own words they "don't trade PRNs or operate compliance schemes", which they position as making their reporting impartial. They will still register you, report for you and even pay your scheme fees.
There are two ways in, and they are sized differently. Their platform, my.ecoveritas, is introduced as software for small and medium-sized businesses, with a free account and prices shown after signup. The managed service carries the large accounts.
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Best for brands with a long SKU tail and packaging data spread across many suppliers.
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What it does for a brand owner collects and matches supplier data, validates weights, calculates, then registers, reports and can pay the fees.
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Who gets the packaging data they do, at scale, by their own count over 32,000 supplier requests a year.
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Markets and streams global packaging EPR data by their own account, with WEEE and battery calculations, and UK compliance delivered through their alliance with Veolia.
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Pricing no published price, though the platform starts with a free account rather than a sales call.
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Watch-out they do not generate an EU Declaration of Conformity. Their PPWR deliverable is an obligation assessment plus a conformity report template, so the declaration stays your job. We compare the two approaches in Repax versus Ecoveritas.
4. PCX Solutions
PCX Solutions is the one on this list whose published customer roster is almost entirely consumer brands, and it shows in what the product optimises for.

Their three stated jobs are mapping packaging data to SKUs, business units and compliance markets, preparing and filing jurisdictional reports, and making packaging decisions that reduce fees. Named features include a SKU packaging library, fee projections and fee allocation by SKU.
That last one is the tell. Allocating fees down to a SKU is what a brand needs when a category manager asks why one product line got more expensive.
Coverage is the widest here in a way that matters if you sell outside Europe. They name 49 or more EPR markets, spanning six US states, seven Canadian provinces, every EU member state plus the UK, eight Asia-Pacific countries, and Turkey, Kenya and South Africa.
Their published client list is Johnson & Johnson, Colgate-Palmolive, Starbucks, Kimberly Clark, Mondelez International and L'Oreal, which is a fair signal of the size of buyer they are built for.
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Best for large brands reporting across North America, Europe and Asia-Pacific that need fees attributed by SKU and business unit.
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What it does for a brand owner keeps a SKU packaging library, projects and allocates fees, tracks regulatory status, and in their words prepares and files the jurisdictional reports.
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Who gets the packaging data you map it in, they calculate and file from it.
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Markets and streams 49 or more EPR markets globally, focused on packaging and plastic.
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Pricing no public price.
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Watch-out their EPR page does not mention the EU Declaration of Conformity, recyclability grades or supplier data collection, so treat the PPWR conformity layer as a separate purchase. Our Repax and PCX Solutions comparison covers where the two fit together.
5. Assent
Assent exists for the version of this problem where the data is not missing so much as unanswered.

Their packaging solution is built around getting suppliers to respond, with multilingual education and one-to-one support, ready-made outreach and tailored information requests, collecting materials, weights and recycled content percentages per SKU.
From that they produce report-ready outputs with fee estimates and jurisdiction-specific reports.
The scope is worth reading carefully before you shortlist them. The regulations named on the page are North American, California SB54, Oregon SB582, Colorado HB22-1355 and Canada's Federal Plastics Registry, and the page is titled for manufacturers.
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Best for brands whose exposure is mainly North American and whose packaging data is stuck with suppliers who do not reply.
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What it does for a brand owner runs the supplier engagement, centralises SKU and packaging attributes, estimates fees and generates jurisdiction-specific reports.
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Who gets the packaging data they do, through a supplier engagement programme rather than a form you fill in.
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Markets and streams global platform with the packaging stream anchored on North American rules.
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Pricing quote only.
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Watch-out EU PPWR, the declaration and recyclability grades are not mentioned on their packaging EPR page, and they do not state that they submit reports for you. Repax versus Assent sets the two side by side.
6. Ecosurety
Ecosurety is a UK compliance scheme whose client list reads like a supermarket aisle, which makes it a natural fit for brands whose biggest market is Britain.

They name Kellogg's, Innocent, Lush, Dr Martens, Clarks, John Lewis and Princes Group among more than 500 major brands, and they have been a UK scheme for over 20 years.
The data operation is the substantial part. They run over 220 validation checks between ingestion and calculation, hold ISO 27001 with full audit logs, and take data as raw files, through their Ecosurety Collect tool, or by direct sync including cloud-to-cloud and bespoke APIs. Their own figures put 5.5 million rows through a single submission.
They also submit, in the UK and internationally, which is the piece a software-only tool leaves with you.
For a brand the sharpest reason to talk to them is the UK recyclability assessment. They screen your data to avoid an automatic red status and publish a component checker, and one case study frames a large retailer clearing unknown statuses as unlocking 27 million pounds in expected fees avoided.
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Best for brands whose largest market is the UK and who want the recyclability assessment sorted and the submission handled.
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What it does for a brand owner validates packaging data at scale, screens it for the UK recyclability assessment, calculates, and submits to the authorities.
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Who gets the packaging data shared work, with their own collection tool and supplier outreach alongside direct syncs from your systems.
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Markets and streams UK packaging, plastic packaging tax and deposit return first, with international coverage arranged per country and priced as a flat charge per country per year.
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Pricing no published figure, quoted for UK services.
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Watch-out they do not produce an EU Declaration of Conformity, naming it as the producer's duty while selling data and guidance around it. See Repax versus Ecosurety for the split.
Match a tool to how your packaging gets made
Company size matters less here than the shape of your supply chain, because that is what decides where the data has to come from.
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A co-packer makes and fills everything. Your priority is a versioned spec you control, so the answer is a data layer plus a standing request to your co-packer, not an annual data hunt.
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You fill on your own line. You already hold the component data, usually in production paperwork. Structuring it is the whole job, and this is the cheapest situation to solve.
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You license the brand or co-brand the pack. Read Article 3(13)(a) with your contract next to it. The extra trademark does not move the duty, so agree in writing who produces the data.
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You supply a retailer's own label. The retailer is the manufacturer for those lines. Expect their template and their deadline, and keep your own brand's data separate from theirs.
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You are a micro-enterprise with a domestic supplier. Check Article 3(13)(b) before you buy anything. The declaration duty may not be yours at all.
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You sell into North America as well as the EU. The register count, not the feature list, is the constraint. Look at the two tools here with published multi-continent coverage.
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Your packaging changes every season. Recyclability scoring and spec versioning matter more than reporting polish, because each change is a paperwork event.
The six tools in one table
Here is the same comparison in one place, with the data question and the price side by side.
| Tool | What it does for a brand owner | Who gets the data | Pricing |
|---|---|---|---|
| Repax | Holds each pack as components and produces the report and the declaration | You, by API, file or connector | Public, free tier, from 29 euro a month |
| Recyda | Scores recyclability and issues declarations plus Annex VII summaries | You upload, they score | Demo only |
| Ecoveritas | Collects and validates supplier data at SKU scale, then reports | They do, 32,000 plus requests a year | Free account, then quoted |
| PCX Solutions | Maps SKUs to markets, allocates fees, prepares and files | You map, they calculate | No public price |
| Assent | Runs supplier engagement, then estimates fees and reports | They do, via a supplier programme | Quote only |
| Ecosurety | Validates UK data, screens recyclability and submits | Shared, their tool plus your syncs | Quoted, per country internationally |
Frequently asked questions about EPR software for consumer brands
These are the questions brand owners ask first once they realise the duty is theirs.
What is EPR software for consumer brands?
It is software that holds the specification of every pack you put your name on, works out what each market wants reported about it, and produces those reports. For a brand the defining feature is component-level data, because the pack was made by someone else and the report is not about your product, it is about its packaging.
Does my brand carry the duty if a co-packer makes the packaging?
Yes, in almost every case. Article 3(13)(a) of Regulation (EU) 2025/40 makes the company that has packaging designed or manufactured under its own name or trademark the manufacturer, and it says so "regardless of whether any other trademark is visible" on the pack.
Your contract can make the co-packer responsible for giving you the data. It cannot move the legal duty.
Can a small brand be exempt?
Only under one narrow rule. If you are a micro-enterprise, meaning fewer than 10 staff and turnover or balance sheet under 2 million euro, and your packaging supplier is in the same member state as you, then Article 3(13)(b) makes the supplier the manufacturer instead.
Miss either half and the duty is back with you. Being small is not on its own an exemption, and the EPR registration thresholds some markets apply are a separate question from this one.
Is there free EPR software for a consumer brand?
Partly. Repax has a free tier at 0 euro a month, and Ecoveritas opens their platform with a free account and shows prices after signup. Neither free option includes anyone filing on your behalf, and no register waives the fees themselves.
Do I need separate software for the EU Declaration of Conformity?
Not necessarily, but check, because it is the most common gap on this list. Reporting tonnages to a scheme and declaring conformity under PPWR are two different jobs off the same pack data.
Of the six tools here, Repax and Recyda publish a declaration feature. Ecoveritas and Ecosurety both name the declaration as your duty and sell data around it. PCX Solutions and Assent do not mention it on their EPR pages. Our declaration checklist covers what the document has to contain.
Should a large brand use an enterprise compliance platform instead?
It is worth pricing, with one caveat. The broadest enterprise option, Sphera, covers more schemes than anything here but advertises no software-only tier, so you are buying consultants and a platform together, which is a different purchase from software your team runs.
If that model suits you, our roundup of enterprise EPR compliance software compares those platforms properly.
Who signs the declaration at a brand?
Someone who can bind the company, since the declaration states that the packaging meets the requirements and carries a dated signature on behalf of the manufacturer. In practice that is a director or a delegated compliance or quality lead, named in writing.
It is not your co-packer, and it is not your PRO. They can supply evidence for the file, but the declaration is issued in your name.
When do we need this in place?
The declaration and the technical documentation apply to packaging placed on the EU market from 12 August 2026, when Regulation (EU) 2025/40 starts to apply.
After that, two dates shape a brand's roadmap. The harmonised sorting label applies from 12 August 2028 or 24 months after the implementing acts, whichever is later, and the recyclability grade floor arrives from 1 January 2030 or 24 months after the delegated acts, whichever is later. Both change the pack itself, so they need design lead time rather than a reporting deadline.
