How to choose a producer responsibility organisation (PRO)

Stella Winther Stella Winther
11 min read

Most producers assume the choice is theirs to make, and in several European markets it is not. Here is how to find out whether you have a real choice, and how to compare the organisations that are actually authorised to take your obligations on.

Three identical office buildings side by side, the middle one in gold with a gold check mark above it, showing one producer responsibility organisation chosen out of three

A producer responsibility organisation, or PRO, is the body that takes on your recycling and reporting duties for one waste stream in one country, in return for a fee. By the end of this guide you will have chosen one, with a written record of why.

It is for anyone who already knows extended producer responsibility (EPR) applies to them and now has to decide who carries it. Budget a few days per market, most of it spent reading documents a PRO must publish by law.

What to have ready before you contact anyone

Every serious candidate will ask you the same handful of things, and one who does not ask cannot give you a quote worth comparing. Write the answers down once, as a short brief you send to all of them.

Line in your brief What goes in it
Countries Every country where you place products on the market
Streams Every waste stream your products fall under, packaging included
Volumes Last year's tonnage per material, plus your estimate for this year
Product plans Anything changing in the range, because fees follow materials
Channels Whether you sell direct, through retailers, or on marketplaces
Today's setup Who reports for you now, if anyone, and when that contract ends

If your tonnage numbers are shaky, fix them before you send anything out. Working out your EPR fees runs on the same figures, and a quote built on a bad weight is a quote you will be renegotiating within a year.

How the choice actually gets made

Two things are worth understanding before you start ringing round.

The first is that the duty never leaves you. Under the packaging regulation, producers hold extended producer responsibility for what they place on a market, and a PRO carries those obligations out on their behalf. If your PRO files late or files the wrong numbers, the regulator still comes to you.

The second is that most of the comparison is desk work. EU waste law already makes a collective scheme publish four things about itself. Those are what producers pay into it per unit sold or per tonne placed on the market, who owns it, who its members are, and how it selects its waste contractors.

From 12 August 2026, packaging PROs must also publish each year the tonnage they handle and the recycling rates they achieve. So a scheme that will not tell you what it charges is not guarding a secret, it is failing an obligation.

The six steps below build one scorecard with a row for each candidate. Only the last two need a conversation with a salesperson.

Step 1. Find out whether your market gives you a choice

Start here, because in a fair number of countries there is nothing to shop for. National governments decide how many organisations may be authorised, and the answer ranges from one to several dozen.

European markets fall into three shapes.

  1. One state concessionaire. A single organisation holds a national mandate across every stream. Hungary has worked this way since July 2023, when the state handed a 35-year waste concession to MOHU, so a Hungarian obligation means signing up with MOHU. Iceland is similarly centralised.

  2. One approved organisation per stream. Several smaller markets license exactly one body for packaging, one for batteries, one for electronics. Your only real decision is which streams you have to sign up for, and you can read that off your product list.

  3. Competing organisations. As of mid-2026, Germany has around ten packaging systems taking members, Spain has a crowded field of its own, and France runs a separate authorised body per product family. Here the choice is real and worth doing properly.

Find your market's shape before you plan any work, because it decides whether the rest of this guide takes an afternoon or a fortnight. Our country overview is the quickest way to see which shape you are dealing with, and the pattern can differ by stream inside one country.

Three market shapes side by side, one national organisation, one organisation per waste stream, and several competing schemes with one picked

Step 2. List every stream and country that needs cover

A PRO is authorised for one country, and its coverage is defined by the products and materials it handles. So a membership does not travel. Selling the same product into three countries means three arrangements, even when one group owns schemes in all three.

Take your brief and turn it into a grid, one column per country and one row per stream. Mark the cell wherever you place products on that market.

Most producers find more marked cells than they expected, because a single product usually spans several streams at once. A cordless drill is electronics, batteries and packaging in the same box, and each of the three may be handled by a different organisation.

Country-specific streams then sit on top of the EU-wide ones. Textiles, tyres, furniture and graphic paper are live in some markets and not others, and the full stream list shows which is which.

Finish the grid before you go looking for names. A marked cell with no candidate against it is exactly the gap that turns into a fine.

Three waste streams set against three countries, six cells needing a scheme, and Polish packaging marked in gold as having no scheme yet

Step 3. Get the candidate list from the regulator

Search results are not a shortlist. An organisation has to be authorised by the national competent authority before it can take your obligations on, and from 12 August 2026 that authorisation becomes a formal EU-wide requirement for packaging.

Each country also has to appoint an independent supervisor to watch how its authorised organisations perform. Which means an official list exists in most markets. Pull it from the regulator rather than from a comparison site.

Market Where the list lives
Germany ZSVR overview of system operators
United Kingdom GOV.UK register of packaging compliance schemes
Denmark DPA list of compliance schemes
France ADEME list of authorised bodies per product family

Elsewhere, start from the national producer register for that country and stream, since the same authority usually publishes both.

Check the date on whatever list you pull. Authorisations can be revoked when an organisation stops meeting the requirements, and a name that was approved two years ago may not be approved today. A cached PDF from 2024 is not evidence that a scheme is still licensed.

Two columns comparing a regulator's own register of authorised schemes against a search result or directory listing

Step 4. Ask every candidate exactly the same things

Send the identical brief and the identical list of asks to everyone on your shortlist. Vary what you ask and you get answers you cannot line up next to each other, which is how producers end up choosing on how much they liked the salesperson.

Before you write to anyone, read what is already published. A collective scheme has to make its ownership, its membership, its fee basis and its contractor selection public, so those four are homework rather than questions. Ask about the things that are not published.

  1. Which of my streams and countries can you actually cover, in your own name. Some schemes subcontract other markets through a partner network. That can work fine, but you want to know who holds the obligation.

  2. What do you need from me, in what format, and how often. A monthly upload in a fixed template is a very different workload from an annual spreadsheet.

  3. How is my fee built up. You want the components, not a single number. Weight times material rate is the base, and eco-modulated fees adjust it for how recyclable the packaging is.

  4. What happens when my products change mid-year. New materials, a supplier swap or a discontinued line all move your numbers, and schemes handle mid-year corrections very differently.

  5. What do you do if my data is queried or audited. Ask what they hand over, what they expect you to produce, and how far back they keep it.

  6. How do you treat a small member. A PRO cannot place a disproportionate burden on a producer of small quantities, and it has to treat producers equally regardless of size or origin, so a minimum fee that dwarfs your actual tonnage is worth challenging rather than accepting.

Put the answers straight into your scorecard while they are fresh, and note who dodged a question. That is data too.

Two columns splitting what a scheme must already publish from the six questions a producer has to ask each candidate

Step 5. Compare the terms you will live with rather than the headline fee

Fees are the first thing producers compare and usually the least useful. EU law caps what a scheme can charge at what is genuinely needed to run cost-efficient waste management, and in some markets the fees are set or approved by the authority rather than by the scheme itself.

So the rate card is often close to identical across your candidates. The differences that actually cost you money are operational.

Score every candidate on the same six lines and you will see them separate.

Line on the scorecard What a strong answer looks like
Coverage Every stream and country you marked in step 2, held in their own name
Reporting load A cadence and file format your team can produce without a special project
Fee transparency A published rate card you can recalculate yourself from your own tonnage
Change handling A defined route for mid-year corrections, without a penalty for using it
Audit support They state what they submit for you and what they will need from you
Exit terms Notice period, and your data handed back in a usable format

Two more checks are worth making before you sign. Ask whether their financial guarantee is in place. That is the security covering waste management costs if the organisation fails or becomes insolvent, it is a condition of their authorisation, and they should be able to say yes without hesitating.

Then ask how they keep your figures confidential. Your tonnage per product is commercially sensitive, and a scheme is required to protect information that can be traced back to an individual producer.

Write a short paragraph naming your pick and the two runners-up, with the reason. When someone asks in three years why you are with this scheme, that paragraph is the answer, and it saves you re-running the whole exercise.

A scorecard with six lines scored across three candidate schemes, scheme A meeting every line

Step 6. Sign up and then make the membership visible where it counts

Signing the contract is not the end of it. The scheme takes on the collection and reporting work, but your name still has to appear in the right place, and who puts it there varies by country.

  1. Sign and get your membership number. Keep it with your company records, because you will be asked for it by marketplaces, retailers and auditors.

  2. Check whether the scheme registers you or you register yourself. In the UK a compliance scheme registers you with the environmental regulator, so you do not do it separately. In Germany you must be in the packaging register in your own name before a system will take you. Assume nothing and read the rule for your market.

  3. File the first report through them, and check it. Your first submission is where a mismatch between your data and their template shows up, while there is still time to fix it.

Registering for EPR covers the register side in detail, and EPR reporting covers what you send once the membership is live. Both steps still belong to you even when a scheme handles the filing.

If you are earlier in the process than this, getting started with EPR compliance covers the ground that comes before picking a scheme.

A four stage chain from signed membership agreement to membership number to national producer register to a first checked report

Where Repax sits next to your PRO

Repax is not a producer responsibility organisation, and it will not join one for you. Choosing a scheme and signing with them stays your decision. What Repax removes is the data work that sits underneath whichever schemes you end up in.

  • One product spec, every scheme's format. Repax Core holds each product broken down to materials and components once, then generates the report in the shape each scheme asks for. Adding a second country becomes another export instead of another spreadsheet.

  • Tonnage you can defend in a quote. The same structured data that produces a report produces the volumes you put in your brief, so candidates are quoting on real figures.

  • Documentation attached to the product it belongs to. Certificates and specs sit on the product record, which is what schemes want when they query a line or grant a lower rate for recyclable packaging.

  • Switching costs less. Because the product data is not shaped around one scheme's template, changing scheme means a new export rather than rebuilding your records.

Explore Repax Core One product spec, exported in whichever scheme's shape you sign with

Filing and enrolment happen outside Repax, on purpose. If you want to see the shape of it first, the pricing page includes a free tier you can put a handful of products through.

Common mistakes when choosing a producer responsibility organisation

These are the traps worth holding your shortlist up against before you sign anything.

  1. Assuming one membership covers a region. Authorisation is national. A scheme with offices in five countries usually holds obligations in one and partners for the rest.

  2. Forgetting a stream. Packaging is the one everyone remembers. Batteries inside a product, and the electronics around them, get missed and then surface as a backdated bill.

  3. Comparing headline rates in a regulated market. Where the tariff is state-approved, the rate card is nearly the same everywhere, and the real cost difference is in the reporting workload.

  4. Confusing a scheme with an authorised representative. A non-EU seller often needs both, and appointing one does not satisfy the other.

  5. Treating a scheme's word as the register. In many markets you still have to appear in the producer register yourself, and a membership certificate is not a registration.

  6. Signing without reading the exit clause. Check the notice period and whether you get your own reported data back in a usable form, because neither is always what you would assume.

Frequently asked questions about choosing a producer responsibility organisation

Short answers to what producers ask most when they reach this decision.

How long does this take

Two to five working days per market once your tonnage data is in order. Where the market has a single authorised organisation, it is an afternoon. The waiting afterwards is on the scheme's side, since onboarding and your first reporting window depend on their calendar.

Do I have to join one at all

In principle no, in practice almost always yes. The rules let a producer carry its own obligations, but then you apply for the authorisation yourself, and you have to show the collection arrangements, the recycling capacity and the financial guarantee a scheme would provide.

Some countries also make joining a scheme compulsory outright. Check your market before assuming you have the option.

Can one PRO cover more than one country

Not in its own name. Authorisation is granted per country, so a group operating in several markets holds a separate authorisation in each, or partners with a local organisation. Ask which of the two applies in every country on your list, since it decides who is accountable when something goes wrong.

Is a producer responsibility organisation the same as an authorised representative

No. A scheme carries out your collection and reporting duties. An authorised representative is the legal presence a producer selling into a country from outside it has to appoint there. A non-EU seller commonly needs both, and some organisations offer the two as separate services.

How does choosing work in the United Kingdom

Differently from the EU. A UK producer either registers itself on the packaging data service or joins a compliance scheme from the GOV.UK register, and a scheme will register you with the regulator on your behalf.

The PRO role itself is filled nationally rather than chosen producer by producer. PackUK appointed UK Packaging PRO on 23 March 2026 as the producer responsibility organisation for the UK packaging scheme, with the appointment starting 1 April 2026.

Can I switch to a different PRO later

Yes, and producers do, usually at a reporting year boundary. Two things make it painful. One is a long notice period, the other is product data that only exists in the outgoing scheme's template. Check both before you sign, not when you want to leave.

Written by

EPR content curator

I write about Extended Producer Responsibility, which is exactly as glamorous as it sounds. Someone has to translate it for human beings. That someone is me.