How to calculate your EPR fees

Frederik Kiel Frederik Kiel
7 min read

EPR is not one fee but a separate one for each waste stream you are responsible for. This guide covers packaging, the stream most producers start with, so you can work out your fee from the weight, rate and recyclability of each material and check any invoice against your own number.

Editorial flat-vector illustration of an invoice titled EPR fees with a gold total bar, next to a cardboard box and a stack of gold coins, on a deep forest green background

An EPR invoice lands and you have no way to tell whether the number is right. This guide fixes that. By the end you will be able to work out your EPR fees yourself, material by material and market by market, and check any invoice against your own figure.

It is written for a producer who has already registered for EPR and is now reporting, and wants to sanity-check what they pay.

What to gather before you calculate

Below are the four things to have ready before you start. If you have already worked through our EPR reporting guide, you can skip ahead, because a fee is built from exactly the same data you file there.

  1. Your placed-on-market volumes. How many units of each product you sold into each country in the period.
  2. The packaging on each unit, split by material. The weight of cardboard, plastic, glass, aluminium and so on for one unit of each product.
  3. The markets and schemes you belong to. One line per country and per waste stream you are registered for.
  4. Your scheme's current fee schedule. The published rate each scheme charges per material, for the year you are calculating.

That last one is the piece people miss. Every scheme publishes its own rates, they change most years, and they are the difference between a guess and a number you can defend.

How EPR fees are actually worked out

Underneath every scheme, the fee is the same shape. You take the weight of each packaging material you put on a market, multiply it by that material's rate, adjust the rate for how recyclable the material is, and add any fixed charge the scheme sets. Then you repeat it for the next country.

So here is the formula you are building.

fee = (weight of each material x that material's rate, adjusted for recyclability) added up, plus any fixed fee, worked out one country at a time.

The five steps below build that formula one piece at a time. To keep it concrete, one example runs through all of them. A company ships a product in a cardboard box with a plastic film wrap, and places 100,000 units on the market in Germany.

Step 1.

List your packaging and sort it by material

Start with what you actually put on the market, because a scheme never bills you for a "box". It bills you for grams of each material inside it.

Take one unit of each product and write down every piece of packaging on it, then assign each piece to a material the scheme recognises: paper and board, glass, plastic, aluminium, steel, wood. A single product usually splits into two or three materials, and each one is charged at its own rate.

In the running example, one unit is a 200 gram cardboard box plus a 20 gram plastic film wrap. That is two materials, so it becomes two lines in the calculation, not one.

Done when every product you sell is broken into a clean list of materials with nothing lumped together as "mixed".

One product unit split into a 200 gram cardboard box and a 20 gram plastic film wrap, each charged at its own rate

Step 2.

Turn each material into a weight per market

A rate is charged per unit of weight, usually per tonne, so the next job is to turn your per-unit grams into a total weight for each market.

Multiply the weight of each material on one unit by the number of units you placed on that market. Keep it per country, because the same product sold into three countries is three separate weights, not one shared total.

For the example, in Germany:

  1. Cardboard: 200 g x 100,000 units = 20,000,000 g, which is 20 tonnes.
  2. Plastic film: 20 g x 100,000 units = 2,000,000 g, which is 2 tonnes.

Done when you have a weight per material, per country, that you could tie back to your own sales records.

Each material's per-unit weight multiplied by 100,000 units, giving 20 tonnes of cardboard and 2 tonnes of plastic film on the German market

Step 3.

Find the rate for each material and multiply

Now bring in your scheme's published fee schedule and put a rate against each material. This is the step where a guess turns into a real number.

Look up the rate the scheme charges for each material for the year you are calculating, then multiply it by the weight from step 2. The rates below are made up to show the arithmetic, so always swap in your own scheme's published rates.

  1. Cardboard at a made-up €100 per tonne: 20 t x €100 = €2,000.
  2. Plastic film at a made-up €700 per tonne: 2 t x €700 = €1,400.

That gives a base fee of €3,400 for Germany before any adjustment. Notice the plastic costs far more per tonne than the cardboard even though there is ten times less of it. That gap is not an accident, and step 4 explains it. This weight-times-rate charge is what schemes call a weight-based fee.

Done when every material has a rate next to it and you have a base fee for the market.

A ledger multiplying each material's weight by an example per-tonne rate, giving a base fee of 3,400 euros for Germany

Step 4.

Adjust the rate for eco-modulation

The reason plastic film costs more than cardboard is eco-modulation, the one lever that changes your bill without changing your weights.

Eco-modulation moves the rate with how easy the packaging is to recycle, so easy-to-recycle materials are charged less and hard-to-recycle ones more.

It is not optional. The EU Waste Framework Directive makes schemes modulate fees by recyclability, and for packaging the Packaging and Packaging Waste Regulation (PPWR) tightens this from 12 August 2026.

In the example, the film is hard to sort, so the scheme adds a made-up 20 percent penalty. The €1,400 film charge becomes €1,680, lifting the market total from €3,400 to €3,680.

Done when each material's rate reflects its recyclability, not just a flat number.

A recyclability scale with cardboard at a low rate and plastic film at a high rate, a 20 percent penalty raising the film charge from 1,400 to 1,680 euros

Step 5.

Add fixed fees and total each market

The per-material charge is usually not the whole bill, so the last step is to add anything fixed and then total the market.

Most schemes add one or both of these on top of the weight-based fee:

  • A membership or registration fee, a flat annual charge for being in the scheme at all.
  • A minimum fee, a floor you pay even if your weights are tiny. This is why very low volume rarely means a near-zero bill.

Add those to the adjusted figure from step 4, and that is your fee for one market.

Then repeat every step for the next country, using that country's categories and rates, because a material sorted one way in Germany can sit in a different category in France. Your total EPR cost is the sum of the per-country totals, not one number applied everywhere.

Done when you have a defensible figure for each market and a grand total you could put next to an invoice.

A receipt adding the weight-based fee, membership fee and minimum fee check into a per-country total, repeated for each country

How Repax works out your fees for you

Read back over those five steps and notice that almost none of the work is the fee itself. It is preparing the inputs: splitting products into materials, turning units into weights, mapping each material to the right category in each country, and keeping up with rates that change every year. That is the part Repax is built to remove.

  • Spec each product once. In Repax Core you enter a product's materials, weights and components a single time, and it produces the weight-per-material breakdown each scheme needs. Steps 1 and 2 stop being a spreadsheet.
  • Every market from the same data. The same product is mapped to each country's categories automatically, so you are not re-sorting the same box by hand for Germany, then France, then Spain.
  • Fees follow the weights. Because the breakdown is clean and per-country, the fee each scheme will charge falls straight out of it, which makes checking an invoice quick instead of a rebuild.
  • Filing is coming. Repax Comply handles submitting across markets and tracking deadlines. It is on the way, with a waitlist open.

Repax does not make you compliant on its own, and it does not set the rates. It does the data work the fee is built on and leaves the sign-off with you.

Pricing is public (as of July 2026):

Plan Price
Free €0 a month
Paid From €29 a month
Custom For high volume

If you are still choosing a tool, our best EPR software rundown compares the main options, Repax included.

Common mistakes when calculating EPR fees

Most fee surprises come from a handful of repeat errors. Check yours against these before you trust the number.

  1. Charging the whole product, not just the packaging. The fee is on the packaging material, so use the weight of the box and the wrap, never the weight of the goods inside.
  2. Using one country's rates everywhere. Rates, categories and eco-modulation rules are set scheme by scheme. A German number does not carry over to France.
  3. Forgetting eco-modulation. Applying a flat rate misses the penalty on hard-to-recycle materials, which is exactly where fees are rising fastest.
  4. Assuming low volume means no fee. Membership and minimum fees mean even a small producer pays a floor, so a near-zero estimate is usually wrong.
  5. Confusing a deposit with a fee. A deposit-return deposit on a drink is refundable and handled by the deposit system. It is separate from the EPR fee you pay the packaging scheme, so do not count it twice.

Frequently asked questions about EPR fees

Short, self-contained answers to what producers ask most about the cost.

How long does it take to calculate your EPR fees?

Once your packaging data is clean, a single market is usually an hour or two of arithmetic. The time goes into preparing the inputs, mainly splitting products into materials and finding each scheme's current rates. The first market takes longest, and every one after it reuses most of the same data.

Do I need the scheme's exact rates or can I estimate?

For a rough budget you can estimate from last year's rates, but for a figure you will put next to an invoice you need the scheme's published rates for the year in question. They change most years, and eco-modulation can move a single material's rate up or down noticeably, so an old rate card quietly drifts out of date.

Why are my EPR fees different in each country?

Because every country runs its own scheme with its own rates, its own material categories, and its own eco-modulation rules. The same packaging can land in a different category and attract a different rate in each market, which is why the fee has to be worked out one country at a time rather than scaled from a single total.

Can I lower my EPR fees?

Yes, mostly through design. Because fees are eco-modulated, making packaging easier to recycle, lighter, or free of problem materials lowers the rate applied to it. Reducing the weight you place on the market lowers the base. Both feed straight back into the formula in steps 2 to 4.

Can Repax calculate my EPR fees for me?

Repax Core produces the weight-per-material breakdown in each country's categories that a fee is calculated from, so the number falls out of your product data instead of a manual spreadsheet. It does the calculation groundwork and leaves the final sign-off with you.

Written by

Co-founder of Repax.io

Frederik Kiel is Co-Founder and Chief Technology Officer at Repax, where he architects technology solutions that bridge the gap between regulatory compliance and sustainable business practices. He focuses on building scalable infrastructure that transforms complex environmental responsibilities into actionable insights. With a commitment to better technology as a force for environmental stewardship, Frederik works at the intersection of compliance innovation and circular economy advancement.