How to reduce your EPR fees in 2026

By the end of this guide you will have a shortlist of the changes that actually lower your EPR fees, in the order they pay off. It is written for a producer who already reports and pays, and who has looked at an invoice and wondered which parts of it are under their control.

Some of these changes land on your next report. Others land on your next production run. Both are worth doing, and one is a lot faster than the other.

What to pull out of your last fee statement

Every saving below is measured against what you paid last time, so start by breaking that number into pieces you can act on. If your invoice only shows a total, ask your scheme for the detail behind it.

1. The fee split by material. Paper, plastic, glass, aluminium, steel and wood are charged at their own rates, and the split tells you which material is really driving the bill.
2. The fee split by market. One line per country, because every country prices the same box differently.
3. The tonnages you declared. The weights that went into your EPR report for the period, per material and per waste stream.
4. How each weight was produced. Note next to each one whether it was weighed, estimated, or carried over from last year.
5. Any adjustment already applied. Bonuses, penalties, membership charges and minimum fees, listed separately from the weight-based part.

Most producers can answer the first four and stall on the fifth. That last one is usually where the quickest saving is hiding, because an adjustment you cannot explain is an adjustment nobody is managing.

Where a fee can actually be reduced

An EPR fee has two inputs you control. One is the weight of packaging you are recorded as placing on a market. The other is what that packaging is made of and how easy it is to recycle, which sets the rate applied to that weight.

The rates themselves are not yours to move. Schemes publish them and you do not negotiate them, so the job is making sure the right weight meets the right rate.

The rate side moves through eco-modulation, the mechanism that charges hard-to-recycle packaging more and easy-to-recycle packaging less.

That is not a scheme's own idea. The EU Waste Framework Directive already requires collective schemes to modulate what producers pay by recyclability, durability, reusability and the presence of hazardous substances.

The six steps run in payback order. Steps 1 to 3 fix the weight side using data you already hold, and they show up on your next report. Steps 4 to 6 fix the rate side, and they show up when your next design or sourcing decision does.

Step 1. Rebuild your last bill line by line

Start by reproducing the invoice yourself, because a saving you cannot locate is a saving you cannot prove.

Lay the statement out as one row per material per market, with the declared weight and the charge next to each other. Work out what each row costs per tonne, then sort the whole thing by what it cost you.

Most producers find that two or three rows carry the bulk of the bill. Those rows are the only ones worth spending real time on.

If your own figure and the scheme's figure disagree, that gap is the first thing to chase. Our guide to calculating EPR fees walks through the arithmetic in detail.

Step 2. Take out the packaging that was never chargeable there

Before improving anything, check that everything on the report belonged there in the first place. This is the cheapest correction available, because nothing about your packaging has to change.

Three groups are worth checking row by row.

1. Packaging that is out of scope in that market. Germany, for example, charges system participation on packaging that typically ends up as waste with private consumers, which leaves transport packaging, reusable packaging and deposit-bearing single-use drinks packaging outside it. Other markets draw the line elsewhere, so check the local rule rather than copying Germany.
2. Goods that were exported again. Producer responsibility attaches where packaging is first made available on a market. Stock that leaves your warehouse for another country is that country's report, not the one you are filing.
3. Packaging whose duty sits with someone else. Some packaging arrives already licensed by the supplier, and some sales through a marketplace are handled by the platform. Confirm it in writing rather than assuming, then stop declaring it twice.

Anything you take out here has to be documented, because you may be asked to show why a tonne disappeared. If you are unsure which duties are yours at all, start with our guide to getting started with EPR compliance.

Step 3. Replace estimated weights with weighed ones

Now improve the numbers that remain. Estimated packaging weights are almost always rounded up, and you pay for every gram of that caution.

Take one physical unit of each product on your heaviest rows, pull the packaging off it, and weigh each component on a scale that reads to the gram. A cardboard box, a plastic film, a label and a strip of tape are four separate lines, each charged at its own rate.

Then multiply by the units you actually shipped into each market, not the units you produced.

Two habits keep the saving. Record the weights against the product itself so the next report reuses them, and keep the evidence, since a lower declared weight only holds up if you can show where it came from.

Step 4. Claim the discounts your scheme already offers

Most schemes already charge less for packaging that is easy to recycle, and a lot of producers ship packaging that qualifies without ever being priced for it.

Read your scheme's current modulation criteria, then check which of your products already meet one. The three largest markets show how differently this is done.

1. United Kingdom. PackUK rates household packaging red, amber or green under the Recyclability Assessment Methodology, and modulated fees begin with the 2026 to 2027 financial year. Red material is charged 1.2 times the amber fee that year, rising to 1.6 times and then 2.0 times over the two years after it, and green material receives a discount funded by what red pays. Large producers have to run the assessment and report the result, so a green product that is never assessed is charged as though it were not green.
2. Germany. Dual systems are required by law to build their fees so that recyclable materials and the use of recyclates cost less. What counts as recyclable is measured against a minimum standard the packaging register publishes with the environment agency every year, currently the 2025 edition.
3. France. Citeo has modulated household packaging fees since 2011, with penalties aimed at elements that disrupt recycling and bonuses for better design.

Whatever the market, the discount is claimed through the declaration, not granted automatically. That means the classification you report has to match what you actually ship.

Step 5. Take weight and empty space out of what you ship

The rate side takes longer to move, so start with packaging minimisation, the change that lowers your fee in every market at once. Fewer tonnes on the report means a smaller bill under every rate card you are subject to.

Two targets are worth taking first, and EU law is heading for both.

1. Material the pack does not need. From 1 January 2030 the PPWR requires packaging to be designed so its weight and volume are cut to the minimum the pack needs to work, and it bans double walls, false bottoms and unnecessary layers that exist only to make a product look bigger.
2. Air. From the same date, grouped, transport and e-commerce packaging has to keep its empty space ratio at or below 50 percent, and filling material such as air cushions, paper cuttings and foam chips counts as empty space rather than as filling it.

So right-sizing a box cuts the fee twice, once on the board it saves and once on the void fill it no longer needs. The packaging optimisation standard ISO 18602 sets out how to work out the minimum a pack really needs.

Step 6. Redesign whatever is priced as a penalty

The last lever is the slowest and the largest. Packaging that is expensive because it is hard to recycle stays expensive until it is changed, and the direction of travel is that it gets more expensive rather than less.

The PPWR turns recyclability into a graded score. From 1 January 2030 each pack is rated A, B or C, where A means at least 95 percent, B at least 80 percent and C at least 70 percent.

Anything below 70 percent counts as technically non-recyclable and faces restriction. From 1 January 2038 only grades A and B may be placed on the market at all.

Fees follow the same grades. EU-wide modulation by grade starts 18 months after the Commission's design-for-recycling rules take effect, and those rules are due by 1 January 2028.

Three changes move a pack up that scale.

1. Drop to one material where you can. A mono-material pack sorts cleanly, while a laminate of two plastics usually does not.
2. Remove the parts that break sorting. Full-sleeve labels, carbon black pigments, metallised layers and glues that survive washing are what push a pack into the penalty band.
3. Put recycled content in. From 1 January 2030 plastic parts have to carry minimum recycled content, ranging from 10 percent for contact-sensitive non-PET packaging to 35 percent for general plastic packaging, rising again in 2040. Several schemes already price recycled content in.

ISO 18604 covers what makes packaging recyclable in the first place, and our guide to PPWR requirements for plastic packaging covers the plastic-specific rules.

Where Repax fits when you go after the savings

Look back at the six steps and notice that four of them are data problems rather than packaging problems. You cannot take a row out, weigh a component properly or claim a discount unless you know what every product is made of, in every market.

That is the part Repax does.

• One spec per product. Materials, components and weights live against the product itself, so step 3 happens once instead of every reporting cycle.
• Every market off the same data. The same pack is mapped to each country's categories, which is what makes step 2 and step 4 checkable rather than guesswork.
• Savings you can defend. Because the breakdown is per component and per market, a lower declared weight comes with the evidence behind it.
• Filing is on the way. Repax Comply will handle submitting and deadline tracking across markets. It is not live yet and there is a waitlist.

Repax does not set your rates, and it does not make you compliant on its own. It gives you the packaging data the savings are argued from, and pricing is public with a free tier. If you are still choosing a tool, our best EPR software rundown compares the options.

Savings that are not savings

Some of the most popular ways to lower an EPR bill do not survive contact with an auditor. Check your plan against these five before you act on it.

1. Declaring less than you shipped. A lower number is not a saving, it is a misdeclaration, and schemes reconcile declared volumes against audits and against what you told the register.
2. Swapping to a material with a lower rate but more weight. The fee is weight times rate, so a cheaper rate on a heavier pack can cost more than what you started with.
3. Assuming a rating applies without the assessment. In the United Kingdom the green discount follows a Recyclability Assessment Methodology result that a large producer has to run and report. No assessment means no discount.
4. Treating a small volume as no obligation. Under the PPWR a producer below 10 tonnes a year files a reduced data set rather than the full one. It is a lighter report, not an exemption from registering or paying.
5. Counting a container deposit as an EPR fee. A deposit on a drinks container is refundable and belongs to the deposit return scheme. Subtracting it from your packaging fee just makes your figures wrong.

Frequently asked questions about reducing your EPR fees

Short answers to what producers ask most once they start working through the list.

How long does it take to see a lower bill?

The data corrections in steps 1 to 3 show up on your next report, so within one reporting cycle. Design changes in steps 5 and 6 only reach the fee once the new packaging is what you are shipping, which usually means the following year.

Can I fix a year I have already reported?

Often yes. Schemes generally run a correction route for volumes that turn out to be wrong, and in Germany that is a supplementary volume report filed after the year-end deadline. Ask your scheme what their route is, and expect to file the corrections that go against you too.

Will lighter packaging always mean a lower fee?

It lowers the weight-based part of the bill, which is the part most producers pay most of. It does not remove membership charges or a scheme's minimum fee, so a very small producer can lighten their packaging and still see the floor they were already paying.

Does switching scheme lower what I pay?

Sometimes, in the markets that give you a choice, and rarely by as much as people expect, because every scheme in a country works to the same national rules. Compare the terms you will live with as well as the headline rate.

Are EPR fees going up anyway?

For hard-to-recycle packaging, yes. The United Kingdom is ramping its penalty on red-rated material to twice the base fee by the 2028 to 2029 year, and EU-wide modulation by grade follows once the PPWR rules land. Doing nothing is the option that gets more expensive.