In Luxembourg one organisation handles every packaging declaration, and there is no weight below which you can ignore it. The first pack you place on the market puts you in scope.
Most goods sold there arrive from somewhere else, so how much of your catalogue you declare depends on which of your suppliers already report their own packaging. That makes the real test of Luxembourg EPR software how much of that work it takes off you, and below are six providers ranked on it.
One organisation carries every packaging duty in Luxembourg
Luxembourg does not split packaging between competing schemes or run a register you sign up to yourself. There is one approved body, and joining it is how you comply.
Valorlux is the only approved organisation
The amended law of 21 March 2017 on packaging and packaging waste puts packaging under producer responsibility in Luxembourg, and the Environment Agency names a single approved organisation to carry it.
For household packaging you must contract that organisation to perform all of your obligations. For non-household packaging you must contract it for all or part of them.
In both cases Valorlux is currently the only body approved to take them on.
That has a useful consequence. Once you join, Valorlux registers your company with the Environment Agency, so there is no separate producer register for you to find and file into.
Three obligations rather than one
Being a party responsible for packaging brings three duties rather than a single annual report.
- Take-back. Reach a set recycling rate each year for the packaging you place on the market, and manage the waste and the data behind it.
- Information. Tell the Environment Agency what your packaging is and what recycling rates were achieved, and tell consumers how to return and sort it.
- Prevention plan. Write down the measures you are taking to reduce packaging, the goals you are aiming at, inform the public, and produce an annual report on it.
Membership is what discharges all three. Valorlux organises the blue-bag collection, calculates the recycling rates from members' declarations and the recyclers' certificates, and runs the prevention work.
One declaration covers household and industrial packaging
Non-household packaging only became reportable in 2024, under a second approval separate from the household one. It did not bring a second declaration with it.
Household and industrial packaging are reported separately inside the same annual report, in the same portal, on the same date. Existing members had nothing new to join.
The line between the two is worth reading twice if you also sell into Belgium. Luxembourg treats drinks packaging under 10 litres as household and over 10 litres as industrial.
In Belgium that line sits at 20 litres, so the same container can land on different sides of the split in two neighbouring countries.
Nothing is too small to be in scope
Most EPR regimes give small producers a floor to stand on. Luxembourg does not, and that is the single most common thing companies get wrong about it.
There is no minimum weight, no minimum turnover and no minimum number of units. Obligations begin with the first packaging you place on the Luxembourg market.
Compare that with the neighbours and the gap is obvious. Belgium's take-back obligation starts at 300 kg of packaging a year, and its prevention plan only bites in the hundreds of tonnes. Luxembourg's three obligations all start at zero.
The minimum contribution is 50 EUR a year, so the smallest members pay a floor rather than a calculated fee.
Reusable packaging kept in a closed loop carries a Green Dot tariff of 0 EUR per kilogram but still has to be declared, and a member declaring nothing else pays the minimum.
Your suppliers decide how much of your catalogue you declare
Here is the part that makes Luxembourg different from every other market on the EPR software shortlist, and the part a spreadsheet handles worst.
You do not declare imported packaging if the supplier who sent it is already a Valorlux member. Their membership has already covered it, and declaring it again would count the same packaging twice.
So before you can size your own declaration, you have to know which of your suppliers are members and which are not.
The member list is public and long
Valorlux publishes its member list in full, with a filter box, and states that it now has more than 1,600 member companies. The version on the site is a snapshot dated 31 December 2025.
For a country of Luxembourg's size that is a lot of names, and it means the check is genuinely worth doing rather than a formality. Valbase also lets you record supplier relationships directly inside the report.
It changes the arithmetic too
Two of Luxembourg's declaration routes lean on supplier status explicitly.
- Declaring imported goods, you count only packaging from suppliers who are not members.
- Using the waste-container method for industrial packaging, you apply a percentage of non-member suppliers over your total suppliers, and Valorlux asks you to document how you worked it out.
Service packaging follows the same logic. Bought in Luxembourg, your supplier declares it. Bought from a foreign supplier, you check the member list to see whether it falls to you.
A foreign supplier can also take the obligation over for their customer outright, on both the household and the industrial side.
It is a moving target
Memberships change, suppliers change and your catalogue changes, so last year's answer is not this year's answer. That is what makes it a data job rather than a one-off lookup, and it is the reason the ranking below is led by a tool that holds packaging data per product and per supplier.
How far each provider follows one Luxembourg declaration
A Luxembourg declaration runs through five stages, and providers stop at very different points along it. The figure plots where each one stops.
The five stages are working out whether you are in scope, holding your packaging data, tracking which suppliers are members, building the declaration, and joining Valorlux and filing in Valbase.
Repax does not reach the end of that track, and the bar says so. Lovat Compliance and Pincvision both register you and submit on your behalf, which Repax does not do today. What Repax covers is everything up to the moment somebody presses submit.
That is a real trade rather than a ranking error. If your problem is that nobody in the company knows what the packaging weighs, the filing was never the hard part.
What we looked for in Luxembourg EPR software
Five things separated the six, all of them specific to how Luxembourg actually works.
| What we tested | Why it matters here |
|---|---|
| Does their own site name Luxembourg | A small market is easy to leave out of a coverage claim, and a provider who has never written about Valorlux has not done the work |
| Can it hold packaging data per product | The declaration is built from materials and weights per pack, in kilograms, in four industrial materials |
| Does it deal with supplier status | Whether a supplier is a Valorlux member decides what you declare at all, and it changes year to year |
| Does it cover the non-household side | Industrial packaging has been reportable since 2024 and some cheap plans are built for consumer sellers only |
| Who files, and does it register you | Joining Valorlux and filing in Valbase are separate jobs from preparing the numbers |
We did not score anyone on the prevention plan, because none of the six publishes a Luxembourg prevention-plan feature.
The best Luxembourg EPR software ranked
Six providers, ranked on how much of the Luxembourg job each one carries rather than on how big the company is. Where a rival goes further than we do, that is said in its entry.
1. Repax for packaging data held per product and per supplier
Repax starts from the pack. You specify each product down to its components, materials and weights once, and the reports come out of that record rather than being rebuilt each February.
In Luxembourg that matters more than it does in a market with a threshold, because there is no volume below which the data stops being needed. A handful of pallets a year still needs materials and weights.
The supplier point lands here too. Products in Repax carry the supplier they came from, which is the field the Valorlux member check is run against, and it is held per product rather than as one note about the catalogue.
Repax is our own product, which is why it sits at the top of a list on our own blog, so the specifics are the part worth checking.
Repax Core holds the product data and generates the reports, and Repax Declare produces the EU Declaration of Conformity that PPWR requires from 12 August 2026.
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
What Repax does not do is press submit. Joining Valorlux and filing in Valbase are not something it does for you, and multi-market registrations and submissions are Repax Comply, which is not released yet.
- Best for: companies that need materials and weights per pack and per supplier, and are content to file the declaration themselves.
- What it does for a Valorlux declaration: holds pack-level components, materials, weights and unit counts, keeps recycled content per material, generates the reports a scheme asks for for household and industrial packaging alike, and produces the EU Declaration of Conformity through Declare.
- How it handles your suppliers: supplier is a field on the product record, so the member check runs against the catalogue rather than against a memory of it.
- Markets and streams: multi-market and multi-stream, including packaging, with Luxembourg guidance published on packaging EPR in Luxembourg.
- Pricing: Core and Declare both start at 0 EUR a month, with Core's paid tiers at 29 EUR and 59 EUR a month, excluding VAT (as of August 2026).
- Watch-out: it does not join you to Valorlux, does not file in Valbase and does not act as an authorised representative, so if you want the declaration off your desk entirely, two providers below go further.
2. ComplyMarket for a service written around the Luxembourg rulebook
ComplyMarket is the only provider here with a service page built for Luxembourg specifically, and it reads like someone worked through the law rather than adapting a generic EPR flow.
Their page names the three ways you become a party responsible for packaging and adds the service-packaging case.
It also names Valorlux as currently the only authorised organisation, names Valbase, gives the deadline as the end of February and the 50 EUR minimum contribution, and sets out both industrial declaration methods.
The service itself is a preparation service on top of their own compliance software.
They run an applicability check, get you ready to join Valorlux, prepare the annual declaration for household and industrial packaging, and keep a traceable packaging dataset lined up with the methods Valorlux accepts.
- Best for: companies that want the Luxembourg specifics handled by people who have already written them down, without handing over the filing.
- What it does for a Valorlux declaration: applicability check, registration readiness for Valorlux membership, declaration preparation for both packaging types, a packaging dataset aligned to Methods A and B, contribution governance and deadline control for 28 February.
- How it handles your suppliers: they ask for supplier details as an input, describing it as helpful for avoiding double declarations, which is the same double-counting problem from the other direction.
- Markets and streams: several EU markets with country-specific pages, packaging being the centre of gravity in Luxembourg.
- Pricing: no public price, demo-led (as of August 2026).
- Watch-out: they prepare the declaration rather than submit it, they do not offer to act as your authorised representative, and you cannot see a price without booking a call.
3. Lovat Compliance for registering and filing without a phone call
Lovat is a VAT-compliance platform that has built out a real EPR line, and it is the only provider here that sells registration, reporting and an authorised-representative service as three separate products.
They publish a Luxembourg EPR guide, and it gets the two things right that most summaries get wrong. It says there is no minimum quantity, and it says Luxembourg does not currently require a foreign company to appoint an authorised representative.
Their reporting product is sold around store integrations and says plainly that it files your EPR reporting for you. The headline figures on that page are their own marketing claims rather than measured results, so read them as such.
- Best for: online sellers who already handle VAT in several countries and want EPR registration and filing to sit in the same place.
- What it does for a Valorlux declaration: EPR registration, EPR reporting with submission on your behalf, and a separate authorised-representative service for the markets that require one.
- How it handles your suppliers: nothing on their site describes tracking which of your suppliers already report, so this stays your job.
- Markets and streams: wide country coverage with per-country EPR guides, alongside VAT, sales tax and marketplace reporting.
- Pricing: quote-led. Their navigation points at an EPR pricing page, but those URLs currently return an error, so there is no figure to quote (as of August 2026).
- Watch-out: their per-country guides are not uniformly current, and the Luxembourg one describes the annual report as going to a ministry when the route in practice is Valorlux and the authority is the Environment Agency.
4. Pincvision for a B2B operation that wants it taken over completely
Pincvision is a Dutch regulatory-reporting provider, and their packaging work sits alongside customs, VAT and Intrastat rather than inside a self-serve app. There is no free tier and no published price.
Their model is stated in four steps and it is fully done-for-you. They identify your obligations per country, handle registrations and local communication, collect and verify your data, and submit your reports.
They are also the provider who published the Luxembourg change that caught B2B sellers out, writing up the extension of scope to industrial packaging and stating plainly that there are no minimum quantities.
- Best for: industrial and B2B companies already outsourcing customs or VAT reporting, who want packaging handled the same way.
- What it does for a Valorlux declaration: obligation identification per country, registrations and correspondence with the scheme, data collection and verification, and submission.
- How it handles your suppliers: their published process covers collecting and verifying data rather than checking supplier membership, so scope the supplier work explicitly when you brief them.
- Markets and streams: packaging, WEEE, batteries, textiles and PPWR, plus environmental registrations and an EPR compliance scan.
- Pricing: no public price, contact-led (as of August 2026).
- Watch-out: there is no self-serve option at all, so a small importer will find this heavier than the job needs, and their own packaging page describes the PPWR switchover loosely.
5. ecosistant for reaching Luxembourg as one of many markets cheaply
ecosistant is the cheapest published route into a lot of countries at once, and Luxembourg is inside their coverage claim rather than called out on a page of its own.
Their Europe plan says it covers 30 countries, listed as all 27 EU member states plus Norway, Switzerland and the UK. Luxembourg is in scope by being an EU member state, which is a weaker basis than a country page but a checkable one.
What you get is guidance rather than someone doing the work. Their self-service is a set of step-by-step guides, kept updated, which is genuinely useful if you have several small obligations and nobody to explain them.
- Best for: small sellers with obligations in many EU countries who want orientation in all of them for the price of one consultant hour.
- What it does for a Valorlux declaration: tells you what applies and how to go about it, with the actual data work and the filing left to you.
- How it handles your suppliers: not covered.
- Markets and streams: 30 European countries for packaging, with add-ons for WEEE and batteries, textiles and furniture, and a separate EU Declaration of Conformity service.
- Pricing: Country plans from 24.90 EUR per country per year excluding VAT, and All of Europe from 399 EUR for the first year across 30 countries, renewing from 299 EUR (as of August 2026). Recycling fees are not included.
- Watch-out: their self-service is aimed at business-to-consumer retailers and points B2B sellers to a contact form, which is awkward in a country where industrial packaging has been reportable since 2024. Their authorised-representative service covers Germany only, and there is no Luxembourg page.
6. ForSURE for a free starting point and the right names
ForSURE is the only provider here with a free tier, and their published country data names all three of Luxembourg's producer responsibility organisations, which is more than most sites manage.
Their Luxembourg entry lists Ecotrel for electricals, Ecobatterien for batteries and Valorlux for packaging. If your first question is who you are actually dealing with, that answer is free.
The limit is that Luxembourg is not one of the countries their free templates are built for. Those are Belgium, Germany and the Netherlands, and the free plan is open to companies under 500,000 EUR of annual gross revenue.
- Best for: a small seller who wants to understand the Luxembourg landscape at no cost before paying anyone.
- What it does for a Valorlux declaration: names the organisation you join and the streams you may be in, with reporting templates built for three other countries.
- How it handles your suppliers: not covered.
- Markets and streams: multi-stream across a list of European countries, with marketplace order sync on the paid plans.
- Pricing: free tier under 500,000 EUR revenue, renewed annually. Paid plans have no published price (as of August 2026).
- Watch-out: no Luxembourg reporting template, categorisation of your own products is a manual step, and there is no self-serve EU Declaration of Conformity tool listed.
Match a provider to where your packaging comes from
Luxembourg decides your duty by how the packaging reaches the market, so that is the useful way to shortlist.
You fill or pack goods in Luxembourg
The packaging is yours from the start and no supplier check reduces it. Everything rests on knowing materials and weights per pack, which is where Repax and ComplyMarket sit.
You import packaged goods from a Valorlux member
Your declaration may be much smaller than your catalogue suggests. What you need is a reliable per-supplier record rather than a bigger service, and the free or cheap options are enough while the list of non-members stays short.
You import from suppliers who are not members
This is the case that grows quietly, because every new supplier can add to your declaration. Hold supplier status per product, and if you would rather not, Lovat Compliance and Pincvision take the whole thing over.
You sell into Luxembourg from abroad
Selling packaged goods directly to Luxembourg households or businesses makes you a party responsible for packaging even with no presence there.
No authorised representative is required today, so the route is Valorlux membership, which Lovat Compliance and Pincvision will arrange.
You produce or import service packaging
Bread bags, pizza boxes, wrapping paper and checkout bags are their own case, and volumes are often counted in units rather than kilograms. Check that whatever you pick can hold units as well as weights.
You make wooden pallets or crates
Manufacturing transport packaging in its final form for the Luxembourg market makes you responsible for it. This is a narrow group and a rare feature, so expect to describe it to whoever you engage.
Your packaging is reusable and stays in a closed loop
It carries a Green Dot tariff of 0 EUR per kilogram, and you still have to declare it. If that is all you have, you pay the 50 EUR minimum and the cheapest option on this list will do.
Every tool measured against a Valorlux declaration
The same six side by side, on the questions a Luxembourg obligation actually asks. Who ends up filing is in the figure further up, so it is not repeated here.
| Provider | Best for | Luxembourg on their own site | Pricing |
|---|---|---|---|
| Repax | Packaging data per product and supplier | Valorlux, thresholds and deadlines | From 0 EUR a month |
| ComplyMarket | The Luxembourg rulebook handled for you | A full service page | Demo-led, no public price |
| Lovat Compliance | Registration and filing alongside VAT | An EPR guide | Quote-led, no public price |
| Pincvision | Handing a B2B obligation over completely | A scope-change article | Contact-led, no public price |
| ecosistant | Luxembourg plus many markets cheaply | Inside a 27-state claim | From 24.90 EUR a country a year |
| ForSURE | A free start and the right PRO names | All three PROs named | Free tier under 500,000 EUR |
Frequently asked questions about Luxembourg EPR software
The questions that come up most often once the shortlist is down to two or three.
What is the best EPR software for Luxembourg?
For most producers it is whatever holds packaging data per product and per supplier, since that is what the declaration is built from, which is why Repax leads this list. To hand the filing over instead, Lovat Compliance and Pincvision both register you and submit.
Do I have to join Valorlux?
For household packaging, yes. The law requires you to contract an approved organisation to perform all of those obligations, and Valorlux is currently the only approved one. For non-household packaging the same applies in whole or in part.
Is there a minimum below which I can ignore Luxembourg packaging EPR?
No. There is no minimum weight, turnover or unit count, and obligations start with the first packaging you place on the market. The minimum annual contribution is 50 EUR.
When is the Luxembourg packaging declaration due?
Always 28 February, for the packaging you placed on the market the previous year. Filing late risks a contractual penalty of 1% of your previous report's contribution for each month of delay.
Do I declare packaging from my suppliers?
Only from suppliers who are not Valorlux members. If a supplier is already a member, their packaging is excluded from your report, and Valorlux publishes the member list so you can check.
Does a foreign company need an authorised representative in Luxembourg?
Not today. A foreign company selling packaged goods directly into Luxembourg is a party responsible for packaging and complies by joining Valorlux. Under PPWR the representative duty applies to distance sellers supplying end users in another member state.
What changes in Luxembourg on 12 August 2026?
PPWR starts applying, and its registration duty can be met by the organisation carrying your obligations, which is how Luxembourg already works. National registers follow the first implementing act rather than appearing that day.
Is household or industrial packaging decided by my customer?
By the packaged product, not the buyer. A television's packaging counts as household even in an office, and for drinks the line sits at 10 litres, which is different from the 20 litres used in Belgium.
