You place packaging, electronic equipment, batteries, textiles or furniture on the market. Under Extended Producer Responsibility (EPR) frameworks now active across the EU and UK, you have obligations toward producer responsibility schemes: declare your volumes, calculate your contributions, and fund the collection and recycling of your products at end of life. It is not optional — and the regulatory landscape is tightening fast.
The challenge: EPR obligations are fragmented across product categories, each with its own product codes, fee schedules, declaration portals and reporting calendars. No ERP vendor has yet shipped a “turnkey EPR module” that covers everything out of the box.
This guide answers the practical question that CIOs and CFOs at manufacturers and importers are asking: what does my ERP need to do to keep me compliant with EPR, and where should I start given my size and budget?
EPR in 2026: Active Categories and the EU Regulatory Framework
Extended Producer Responsibility is embedded in several binding EU directives and regulations. The main frameworks affecting ERP systems today are:
- WEEE Directive (2012/19/EU) — Waste Electrical and Electronic Equipment, applying to manufacturers and importers of household and professional electronics. All EU member states have transposed this into national law, with their own compliance schemes.
- Packaging and Packaging Waste Directive (94/62/EC, revised by PPWR 2025) — Packaging Recovery and Recycling targets for packaging placed on the market. National compliance schemes (Citeo in France, Der Grüne Punkt in Germany, Valpak in the UK) collect and redistribute contributions.
- EU Battery Regulation (2023/1542) — In force from August 2025, it extends EPR to portable batteries, light-vehicle batteries (MTL), SLI starter batteries and industrial batteries. Full declaration obligations apply from 1 January 2026.
- Textile/Clothing EPR — France led with the TLC scheme (Re-Fashion); similar frameworks are being rolled out across the Netherlands, Sweden and Spain under the EU Textiles Strategy for Sustainability.
Beyond these four, furniture, tyres and printed paper each have active EPR schemes in multiple EU countries.
The Categories with the Greatest Impact on Information Systems
Not all EPR categories create the same IT burden. Four of them combine high producer volumes with the most complex declaration requirements:
Packaging (Citeo / Der Grüne Punkt / Valpak) The oldest and broadest EPR stream. It applies to any company that packages products sold to consumers. Fee schedules distinguish materials: recyclable plastic at €339.71/tonne, corrugated cardboard at €148.69/tonne, glass at €7.61/tonne, steel at €26.73/tonne, aluminium at €79.75/tonne (France 2026 published rates as a representative benchmark). Eco-modulations apply: surcharges up to +100% for non-recyclable plastics, discounts up to -12% for recycled content incorporation. Annual declaration deadlines typically fall in Q1.
Waste Electrical and Electronic Equipment (WEEE) Any manufacturer or importer of consumer or professional electronics is subject to WEEE. Under the directive, equipment falls into ten categories (1–10). Member states run their own approved compliance schemes — Ecologic and Ecosystem in France, ear (Stiftung Elektro-Altgeräte Register) in Germany, Valpak and B2B Compliance in the UK — each with distinct 2026 fee schedules and eco-modulation criteria.
Textiles, Clothing and Footwear (TLC/TCF) Manufacturers and importers declare volumes in both units and tonnage. The compliance scheme manages separate collection and reuse flows. The ERP stock management module must distinguish between “new products placed on market” and “returns” flows to prevent over-declaration.
Batteries Battery producers and importers fund collection and recycling. Traceability by reference (size, type, chemistry, brand) is required to calculate per-unit contributions accurately under the new EU Battery Regulation.
Key 2026–2027 Developments: Two Schemes Going Live
Professional Packaging (July 2026 — France; pending across EU) France’s framework decree, published in November 2025, makes registration with an approved compliance scheme mandatory from 1 July 2026 for any company placing transport, groupage or professional-sale packaging on the French market. No size threshold exempts SMEs. Similar frameworks are expected in Germany and the Netherlands under the revised PPWR.
Batteries (in force since August 2025) Decree No. 2024-1221 of 27 December 2024 transposes EU Regulation 2023/1542 and extends EPR to portable batteries, light-vehicle batteries, SLI starter batteries and industrial batteries. Operational from 18 August 2025, with full declaration obligations from 1 January 2026.
What EPR Requires from Your ERP: Five Core Capabilities
No EPR scheme dictates a specific ERP format. But all of them require the same IT capabilities, whether covered natively or through a specialist connector.
1. Product Categorisation Using the Compliance Scheme’s Nomenclature
Each compliance scheme uses its own product nomenclature. Packaging schemes classify by material and format. WEEE schemes use the EU directive’s categories (1–10). Textile schemes distinguish clothing, household linen and footwear.
In the ERP, this translates into additional fields in the product master: EPR stream code, scheme category, primary material, unit packaging weight. These fields must be populated at product creation and kept current with every change in packaging or sourcing.
A dishwasher sold across the EU requires two distinct codings in the product record: the WEEE category (category 2, large household appliances) for the national compliance scheme, and the packaging category (cardboard + plastic + foam) for the packaging scheme.
2. Tracking Tonnage Placed on the Market by Stream and Period
The EPR calculation base is the tonnage of products placed on the market — i.e. delivered to end customers or distributors in a given territory over a given period. This is not the same as units sold: it excludes returns, destructions and exports outside the relevant territory.
The ERP sales module must be able to filter flows by:
- Geographic destination (domestic vs. export)
- Customer type (end consumer, distributor, professional, export)
- Product category (by EPR stream)
- Declaration period (monthly, quarterly or annual depending on the scheme)
This filtering — trivial in theory — is often the main obstacle in ERPs configured without an EPR lens: country codes are sometimes incomplete, customer typologies poorly structured, and declaration periods do not align with financial year ends.
3. Calculating Contributions Due to the Compliance Scheme
Once the tonnage per material category is calculated, the contribution is derived by applying the current fee schedule. But schedules change annually (usually updated in January) and include eco-modulations that depend on product characteristics.
The ERP must therefore maintain an updated fee schedule table, ideally synchronised with official scheme publications. In the most advanced setups (Tier 1 or specialist module), this calculation is automated at period close.
For companies on mid-market ERP without a native EPR module, this calculation is often performed in a spreadsheet populated by an ERP export — functional but fragile. A missed fee schedule update can generate an incorrect declaration.
4. Automated Generation of Declarations
Each compliance scheme operates an online declaration portal. Most accept manual declarations via web portal and, for high-volume declarants, structured CSV imports. Some — including Citeo in France and similar schemes elsewhere — now offer API access for automated submission.
End-to-end automation from the ERP to the compliance portal is technically feasible but rarely implemented outside large enterprises. It requires an API on the scheme side, a connector on the ERP side, and reconciliation logic to detect anomalies before submission.
The reality for most mid-sized companies is a semi-automated flow: the ERP produces a summary file per stream, which an HSE or Finance lead validates before manual import into the portal. This approach remains compliant as long as the source data is reliable.
5. Archiving Supporting Documents and Compliance Certificates
Compliance schemes may request supporting documents during audits. Producers must retain proof of declaration and payment for ten years (aligned with the EU Waste Framework Directive record-keeping requirements). In streams subject to audit (WEEE, batteries), collection and treatment certificates may be required.
The ERP or associated document management system must archive: annual declarations by stream, contribution payment receipts, valorisation certificates issued by compliance schemes, and — for companies operating individual compliance systems — contracts with approved collectors and processors.
Three Approaches to EPR Integration in Your ERP
There is no universal solution. The right choice depends on your ERP, the number of streams you are subject to, and your declaration volumes.
Approach 1: Native ERP Module (Large Enterprises, SAP S/4HANA and Oracle ESG Cloud)
SAP provides EPR coverage through its Product Compliance module (formerly Product Safety & Stewardship) coupled with the SAP Sustainability Control Tower. Configuration allows compliance rules to be defined per product, EPR contributions to be calculated automatically by stream, and compliance reports to be generated. Integration with the SD (sales) module is native: each customer delivery updates the EPR counters in real time.
Oracle offers equivalent functionality in Oracle Fusion Cloud SCM, with a product substance and compliance management module that can be extended to EPR traceability.
Limitations: these modules carry a significant additional licence cost and require expert configuration for deployment. They are relevant for groups with broad EPR scope (multiple streams, high declaration volumes, presence across multiple EU countries each with their own EPR systems).
Approach 2: Specialist Connector for Mid-Market (Dynamics 365, Odoo, Sage X3)
Specialist vendors offer connectors between mid-market ERPs and compliance portals. These solutions retrieve sales and stock data from the ERP via API or structured export, apply current EPR fee schedules, and prepare import files for the relevant schemes.
A typical configuration for a mid-sized company on Microsoft Dynamics 365 Business Central or Sage X3 involves:
- Enrichment of the product master (EPR codes, packaging weight per material)
- Automated extraction of sales flows filtered by territory and customer type
- A contribution calculation engine with current fee schedules
- An export interface to the compliance scheme portal
The cost of this type of solution ranges from €15,000 to €50,000 for initial integration, depending on EPR scope complexity and the desired level of automation.
Approach 3: Standalone EPR Tool + ERP Extract (SMEs, Limited Budget)
For SMEs subject to one or two streams with modest volumes, the combination of an ERP extract (CSV export of sales by product category) and a specialist EPR SaaS tool remains the most accessible approach. These tools maintain current fee schedules, calculate contributions, and enable portal imports.
Companies whose total annual contribution is below €10,000 can typically declare directly on scheme portals without additional tooling: the administrative burden remains manageable manually. Above that threshold, automation pays back within the first year.
EPR Compliance Checklist for Your ERP: 15 Points to Verify
Review these elements in your system before your next annual declaration.
Product Master
- Each active product reference has an EPR stream code (or a documented “not subject” notation)
- Packaging weight by material is populated (cardboard, plastic, glass, metal, other)
- Compliance scheme categories are mapped (e.g. WEEE category 2 for dishwashers)
- EPR fields are kept current with every packaging or sourcing change
Sales Management
- Deliveries to each territory (domestic vs. export) are identifiable by country code or geographic zone
- Customers are typed by nature (end consumers, distributors, professionals, export)
- Returns and credit notes are distinguished from net sales (to prevent over-declaration)
- EPR declaration periods are defined in the sales module configuration
Calculation and Declaration
- Current fee schedules are loaded in the system (updated each January)
- A “tonnage placed on market by EPR stream” summary can be generated without manual reworking
- Contribution calculation is automated or semi-automated (export to calculation tool)
- A single responsible contact (HSE, Finance or IT) is designated to validate declarations before submission
Archiving
- Annual declarations by stream are archived in the document management system or a dedicated space
- Contribution payment receipts are retained
- Compliance scheme conformity certificates are archived (statutory retention: 10 years)
Declaration Errors That Are Costly
Audits by environmental agencies and compliance schemes have intensified since 2023. The most frequent errors have direct financial consequences.
Under-declaration The main cause is incomplete ERP traceability: sales flows not flagged as “placed on domestic market”, product references without an EPR code, secondary packaging not counted. Under-declaration exposes companies to reassessments and late payment penalties. In the most audited streams (WEEE, household packaging), cross-referencing with customs data allows schemes to detect significant discrepancies.
Over-declaration Less frequent but also costly: customer returns counted as sales, exports counted as domestic deliveries. The ERP must precisely filter flows entering the EPR calculation base.
Failure to Update Fee Schedules Schedules change every January. A company applying the previous year’s rates will either under- or over-pay contributions. In both cases, a reconciliation is required.
Specific Challenge for Exporters Manufacturers exporting to Germany, Spain, the Netherlands, Belgium or the UK must register with the local compliance scheme in each country: LUCID in Germany, RAEE in Spain, ARN in the Netherlands, the UK EPR Packaging scheme via the Environment Agency portal. Each country has its own categories, its own fee schedules and its own portals. An ERP configured only for one domestic market does not cover these cross-border obligations.
Budget and Roadmap: Achieving Compliance Before 2027
Cost Estimates by Approach
| Approach | Profile | Indicative Budget |
|---|---|---|
| Native SAP/Oracle module | Large enterprise, SAP S/4HANA or Oracle Fusion | €80–200k (configuration + licence) |
| Specialist connector | Mid-market, Dynamics / Sage X3 / Odoo | €15–50k (initial integration) |
| EPR SaaS tool + ERP extract | SME, 1–3 streams | €3–10k/year (subscription) |
| Manual declaration | SME, total contribution < €10k/year | <€1k/year (portals are free) |
These ranges are indicative. Actual cost depends on product master complexity, number of streams, and target automation level.
The Four Steps of an EPR Compliance Project
Step 1: Map applicable streams (4 weeks) List all your product categories placed on the market in each target territory. Identify the EPR streams concerned (packaging, WEEE, TLC, tyres, batteries, paper, furniture, toys…). Verify your registration with each applicable compliance scheme. This mapping is the prerequisite for any ERP configuration.
Step 2: Enrich the product master (6–8 weeks) This is usually the longest phase. For each active reference, populate EPR stream codes and packaging data. For large catalogues (>10,000 references), a spreadsheet-based extraction followed by a mass import is often required. Define default rules by category for historical references.
Step 3: Configure EPR sales flows (2–4 weeks) Create or adapt reporting views in your ERP to extract sales filtered by territory, customer type, and aggregated by EPR category. Validate consistency against prior declarations (if available) or against accounting estimates.
Step 4: Run a dry-run on a closed period (6 weeks before the next declaration) Generate a test declaration on the most recent closed period. Compare with manually declared amounts. Identify discrepancies and correct parameters. Have the result validated by your HSE or sustainability lead before delivering the first automated declaration.
EPR, CSRD and ESG Data: Convergence Is Accelerating
EPR data does not only serve compliance with producer responsibility schemes. It feeds directly into CSRD reporting (European Sustainability Reporting Standards E5, Circular Economy) and the scope 3 KPIs required by CSDDD for value chain supply-chain principals.
A company that has structured its EPR data in the ERP (tonnage placed on market, packaging recycling rates, contributions paid to streams) already holds much of the circular economy data required by ESRS E5. The investment in EPR compliance is therefore not an isolated cost line: it sits within a sustainability data architecture that simultaneously serves CSRD, CSDDD and the ESG audits of large enterprise customers.
To go deeper on these connections, see our articles on CSRD and ERP: preparing sustainability reporting in 2026, the AGEC law and ERP obligations for brands and CSDDD, due diligence and ERP: supplier traceability and ESG compliance.
