EPR Declaration Deadlines 2026: 11 EU Countries in One Place

Selling packaged products across multiple EU markets means tracking a matrix of different filing cadences — monthly in Spain, quarterly in France and Germany, annual in most others. Miss one, and the late-filing penalties vary from a €50 admin fee to a 10% surcharge to a registration suspension.

This article is a single-page reference for 2026 deadlines across the 11 markets Pack Declare supports. Bookmark it, or use our free EPR Deadline Calculator to export the dates straight to Google / Outlook / Apple Calendar.

The full table

Reading the table

A few practical notes about how PROs interpret their own deadlines:

• The deadline is normally the submission date, not the payment date. Payment invoices follow the declaration and typically have their own 30-day clock from the PRO invoice date.
• Weekends and public holidays don't extend the deadline in most portals — plan for the last working day before each date, not the date itself.
• Monthly portals roll forward: if you miss the February filing for January sales, you can submit it in March but it'll be flagged as late. Monthly gaps are easier to detect than quarterly ones.
• Some portals distinguish household (ménager / domestic) from commercial streams — most notably CITEO. You may have two deadlines per quarter, one per stream.

Late-filing consequences by country

• ES (ECOEMBES): €50 administrative fee + interest on fees owed. Late > 60 days requires a written justification.
• FR (CITEO): 10% surcharge on fees if > 30 days late. Repeated late filings trigger audit.
• DE (LUCID): Registration suspension is possible for repeat offenders. Suspension = legal inability to sell packaged goods in Germany.
• IT (CONAI): Interest on overdue contributo ambientale, plus late-filing sanctions from the Ministry of Environment.
• NL (Afvalfonds): Fines from the ILT (Inspection for Environment & Transport) — typically €5,000 first offence.
• BE, AT, PT, PL, SE, DK: Each PRO has its own schedule; penalties typically start around €500 and scale with the volume undeclared.

How Pack Declare handles deadlines

Pack Declare ships a built-in compliance calendar that:

• Shows every upcoming deadline for every country you have sales in.
• Sends email reminders to your ADMIN + EDITOR users at 30 / 14 / 7 / 1 days out (deduped via Redis so you never get the same reminder twice).
• Highlights overdue cells in red on the dashboard, with a direct link to generate the missing pack.
• Integrates with the Last submitted column on the dashboard so you see at a glance which countries are current.

If you don't use Pack Declare, our free Deadline Calculator exports the same dates to your calendar app at no cost.

Bottom line

There's no way around tracking ~15 distinct deadlines if you sell across the major EU markets. The choice is between doing it in a spreadsheet (where you'll miss one eventually) and letting a compliance tool watch them for you. Either way, the cost of missing is concrete — and usually bigger than the cost of the tool.

Run the free PPWR Compliance Check →

Related reading: The 2026 PPWR compliance checklist · Multi-country EPR strategy · EPR fees explained

Frequently asked questions

Is an EPR deadline the submission date or the payment date?

Normally the submission date. The payment invoice follows the declaration and typically carries its own 30-day clock from the date the scheme issues it, so treat filing and paying as two separate deadlines rather than one.

Do weekends and public holidays extend an EPR deadline?

In most portals, no. Plan for the last working day before each date rather than the date itself. A declaration that only becomes possible to file on a closed banking day is a declaration filed late.

What happens if I miss a monthly EPR filing?

Monthly portals roll forward: if you miss February’s filing for January sales you can still submit it in March, but it will be flagged as late. Monthly gaps are easier for a scheme to detect than quarterly ones, so they tend to surface quickly.

Can one country have more than one deadline per period?

Yes. Some portals separate household from commercial streams, CITEO most notably, which can mean two deadlines per quarter rather than one. Treating a country as a single filing date is a common way to miss half an obligation.

What is the penalty for filing late in Spain?

ECOEMBES applies a €50 administrative fee plus interest on the fees owed. Filing more than 60 days late additionally requires a written justification, so the cost of a long delay is procedural as well as financial.

What is the penalty for filing late in France?

CITEO applies a 10% surcharge on fees when a declaration is more than 30 days late. Repeated late filings trigger an audit, which is generally the more expensive outcome of the two.

What is the risk of late filing in Germany?

Registration suspension is possible for repeat offenders, and a suspended LUCID registration means a legal inability to sell packaged goods in Germany. The exposure is loss of market access rather than a fee.

What are late-filing penalties in the smaller EU markets?

Belgium, Austria, Portugal, Poland, Sweden and Denmark each run their own schedule, with penalties that typically start around €500 and scale with the volume left undeclared. The Netherlands is stricter: ILT fines commonly begin at €5,000 for a first offence.