EPR costs per country are mostly fixed: a representative where required, a setup, and flat-rate eco-contributions that do not scale down below a floor. Eco-contributions themselves are small; the fixed layer is what decides whether a market pays. The exercise is to rank your countries by gross margin, put the fixed EPR cost of each next to it, and register where the margin covers it with room to spare. Blocking a country you cannot justify is legal and common; selling there unregistered is neither, since marketplaces check numbers and fines start at the first unit.
What the cost actually is
- Eco-contributions: per unit or per kilo, at the eco-organisme's tariff. Below a floor, most schemes charge a flat minimum: Léko's 2026 minimum is €95 per half-year for packaging; Refashion has a simplified regime under 5,000 pieces.
- Representative: where required (France for anyone not established there; every EU country for non-EU companies). A fixed annual fee.
- Setup: memberships, catalogue coding, one-off.
- Your own time: declarations, marketplace follow-up, marking. Usually the largest hidden cost when you do it yourself in six countries.
How to rank your countries
For each country, take the gross margin you make there and put next to it the fixed EPR layer: the representative fee where one is required, the setup, and the minimum eco-contributions of each stream at that country's published tariffs. Countries where the margin covers the fixed layer with room to spare are a yes; countries where it barely covers it depend on growth; countries where it does not are candidates for blocking or for a local distributor. In practice two or three countries carry the business and the rest do not pay for their own compliance.
The alternatives to registering everywhere
- Block the country in your shipping settings and marketplace offers. Legal, reversible, and the obligation never arises.
- Sell through a local distributor who buys and resells. They become the producer; you provide packaging data.
- Consolidate into one EU entity for VAT and customs. It does not remove the per-country EPR registrations, and in France it does not remove the representative either.
What not to do
Selling into a country without registering because the volume is small. There is no de minimis in France or Germany; marketplaces verify numbers per country; the French fines under article L. 541-9-5 are per unit. The cheapest non-compliance is not to sell there.
For France, the Free EPR Calculator gives the eco-contribution side at 2026 tariffs, and the pricing page gives the fixed side.
Frequently asked questions
Is there a volume below which EPR does not apply?
Not in France or Germany. Some countries have tonnage thresholds for packaging (Ireland, for instance). Check each country; do not assume.
Can I register in one EU country and be covered everywhere?
No. Registration is per country. The EU packaging regulation harmonises rules, not registers.
What does a small seller pay for French EPR in total?
Minimum eco-contributions per stream at the published 2026 tariffs, plus the mandataire's fixed fee and setup. The Free EPR Calculator gives the first part for your catalogue; the pricing page gives ours.
Is blocking France a bad look with Amazon?
No. Many sellers restrict marketplaces by country. It is a business decision, not a compliance issue.
Sources
- Léko — Barème Emballages ménagers & Papiers 2026 (14 Nov 2025)
- Refashion — Barèmes éco-contribution 2026
- Légifrance — Code de l'environnement
- EUR-Lex — Regulation (EU) 2025/40 (PPWR)
- Eldris — EU EPR Seller Compliance Index 2026 (June 2026)
- Commission estimate of the representative-services market (€1–2 bn/yr), reported Aug 2026
Founder of EPR France Rep, the France-based EPR authorised representative for companies selling into France.
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