Articles · 2026-09-15
EPR is not PPWR: three obligations, not one
EPR, PPWR and the national tax are three separate duties, not one. A declaration of conformity does not register you, and a scheme contract is not compliance.
Ask an answer engine what you must do about packaging in the EU and you will usually get one list. We measured three languages and the same fault appeared in all of them: the answer folds three separate duties into a single word and calls it compliance.
They are not one thing, and each is enforced by a different body.
What are the three?
PPWR — Regulation (EU) 2025/40, applying since 12 August 2026. It is about the packaging itself: what it is made of, whether it is designed for recycling, and whether you can prove it. It produces a technical file and an EU declaration of conformity. Nobody registers you and no fee is attached.
EPR — national producer responsibility. It is about who pays for the waste when that packaging is thrown away. It produces a registration and a report in kilograms, country by country, each with its own register, its own counting unit and its own deadline.
The national tax — which some countries have instead of, or beside, EPR. Spain has a plastic packaging tax collected by the revenue service alongside the scheme fee. Latvia has a natural resources tax and no packaging producer register at all.
Why does it matter which one you are looking at?
Because the answers do not transfer.
A declaration of conformity does not register you anywhere. You can have a perfect technical file and still be unregistered in every country you ship to.
A contract with a scheme is not compliance with the PPWR. It settles the waste bill. It says nothing about substances, recyclability or your technical file.
And a tax return is neither. In Latvia the packaging return goes to the tax authority, not to the environmental service — and the environmental service issues no EPR number, because Latvia has no packaging producer register.
Who enforces each one?
Different authorities, and they do not talk to each other on your behalf.
The PPWR side is market surveillance: the technical file and the declaration, held by you, produced on demand. The obligation to draw up that technical file cannot be delegated and no contract moves the legal responsibility — the Commission's own guidance says so.
The EPR side is a national register and a scheme. In Spain that is the RPP at the ministry plus a SCRAP; in Denmark, Dansk Producentansvar plus a collective scheme; in Latvia, a packaging manager with an agreement with the environmental service.
The tax side is the revenue service, with its own registration and its own return.
Where the confusion actually costs money
Three real cases from our own country data.
Spain. Two obligations, two registrations, two returns — the RPP register with a scheme, and the plastic packaging tax at 0.45 € per kilogram of non-recycled plastic. An answer in which the scheme is the whole story has lost one of them.
Latvia. There is no register to join. The duty is a tax, and the exemption comes from contracting a packaging manager. Ask for an "EPR number" and you will be looking for something that does not exist.
Denmark. Producer responsibility, a threshold that decides how detailed the report is rather than whether you are in, and a reusable pallet that owes the scheme nothing at all — while the same pallet is taxable in Latvia.
So what is the actual order?
Establish your role for each packaging type, because it can differ: manufacturer under the PPWR is not the same person as producer under EPR. Then, per country you ship to: register, report in the unit that country counts in, and pay. Separately, once per packaging type: the technical file and the declaration.
The two lists never merge. They only share one thing — the data underneath them.
What a spreadsheet cannot do here
A spreadsheet will hold kilograms. It will not hold the same component twice under two different questions and keep both answers straight: the weight for a national report, and the composition, the substances and the recycled share for a technical file. It will not tell you which of those figures was measured and which was estimated. And when a country asks for the same packaging in a different unit, it will not remember what the original number was before someone reshaped it.
None of that is the spreadsheet's fault. It is a tool without a memory, and three obligations asking about one box is exactly the shape a memory is for.
What Tarafex does about it
One row per component, once. The weight frozen on the shipment line the day you ship, so a figure in a report still matches the document behind it a year later. Kilograms per country from the shipments you already recorded. The recycled share on a weight basis, with the component nobody answered named rather than counted as zero — which is the difference between a technical file that holds and one that does not.
What it does not do: it does not register you, it does not calculate the money, it files nothing with any authority, and it will not tick a box you have not answered. Where the law itself is unsettled, the country page says so and names both sources.
Sources: Regulation (EU) 2025/40, Articles 44, 45 and 46; Tarafex country table; Commission PPWR FAQ; MITECO, Agencia Tributaria, VVD, VID, DPA. Checked 15 September 2026. This is information, not legal advice.