Articles · 2026-09-25
Can one collective scheme cover several countries?
No. Under Article 47 a scheme is authorised by one member state, so membership, fees and coverage stop at that border. What that means country by country.
What is a collective scheme?
A collective scheme is a producer responsibility organisation (PRO). You pay it a fee, and it takes on the practical side of your packaging EPR duties in one country: paying for collection and sorting, reporting quantities, and in most countries filing the figures the authority asks for. Regulation (EU) 2025/40 calls it a producer responsibility organisation in Article 46. Denmark calls it a kollektiv ordning, Germany a dual system, France an eco-organisme. The words differ; the role is the same.
Is there an international collective scheme?
No. Under Article 47 of the regulation, a producer meeting the obligations on its own, or a producer responsibility organisation meeting them for its members, applies for an authorisation to the competent authority — and a competent authority is appointed by one member state for its own territory. The Commission's own explanatory memorandum to the proposal describes the same rule, and adds that where several organisations exist, the member state must ensure that between them they cover its whole territory.
So a scheme is authorised country by country. Membership of a Danish scheme covers packaging you make available in Denmark. It does nothing for the same pallet in Germany.
Then what are the groups that operate in many countries?
Several groups run a separate, locally authorised company in each country: in our own country table ERP Denmark belongs to the Landbell group, ERP also appears in Austria, Interzero is listed in Austria, Poland and Slovenia and as Interseroh in Germany, and Reclay in Austria, Germany and Slovakia. One brand, one invoice, one account manager — but the authorisation, the fee and the reported quantity still belong to each national company.
A one-stop-shop provider works the other way round: it is not a scheme at all. It signs you up with the national schemes and files on your behalf. Spain says plainly that an adhesion made indirectly through a one-stop-shop service counts the same as a direct one.
Does joining a scheme replace registering?
Registration and membership are two different things, and one does not automatically stand in for the other. Article 44(2) says that where a producer has entrusted a producer responsibility organisation, the obligations of that article are met by that organisation — unless the member state where the register is established provides otherwise. Two countries, two answers, and you have to read the national rule.
Czechia is the clearest case in the other direction: a producer whose EKO-KOM contract covers all of its packaging is not entered in the Seznam osob at all, so the missing entry is lawful, not a breach.
Is membership compulsory?
The regulation leaves it to each country. Article 46(1) lets a member state make participation in a producer responsibility organisation mandatory, and several have. Denmark requires membership of at least one approved collective scheme for single-use packaging. Germany keeps its licensing requirement for packaging that ends up with households. Other countries let you fulfil the obligation individually, on paper at least.
Denmark: what does membership actually mean?
Since 1 January 2025 a registered packaging producer must be a member of at least one approved collective scheme, and the DPA guidance lets you attach a scheme per packaging category and per end-user type. For reusable packaging membership is optional, but registration with DPA is not.
The scheme does not choose its own work: DPA allocates municipalities and packaging fractions to the schemes, and the first allocation period runs from 1 October 2025 to 31 December 2026. An approved scheme has to be able to handle every material fraction.
How many schemes can I choose from?
It depends entirely on the country. Poland has 23 organisations for household packaging, Romania 14, Germany 10, Slovakia 9. Denmark, Estonia, Spain and Portugal have three; Finland, Greece, Lithuania, Malta and Sweden two. Belgium, Cyprus, Czechia, Ireland, Luxembourg and the Netherlands have a single organisation, so there is nothing to choose. Croatia and Hungary run a state fund instead. Our country table lists them by name.
Does one fee cover the same packaging twice?
No. Each scheme charges for the quantity you make available in its own country, and the fee is set by that country's tariff. The same box shipped to three countries is reported three times, to three organisations, under three tariffs. That is not double charging: each country pays for collecting its own waste.
What a spreadsheet cannot do here
A spreadsheet will hold one weight per box. It will not hold the same box three times under three schemes, with three different material splits, three registration numbers and three reporting deadlines — and it will not tell you which of your markets you have no membership in at all.
What Tarafex does
Tarafex keeps one packaging record per item and reads it per country: which member state it was made available in, which scheme covers it there, which register the producer sits in, and what the quantity comes to for each report. The evidence sits under the number.
Sources: Regulation (EU) 2025/40, Articles 44(2), 46 and 47; the Commission's explanatory memorandum to the proposal on authorisation and territorial coverage; DPA's guidance on attaching a collective scheme; Gleiss Lutz on Germany keeping its licensing requirement under Article 46(1); the Commission PPWR FAQ; and our own country table. Checked 25 September 2026. This is information, not legal advice.