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Is there a minimum quantity below which EU packaging EPR does not apply?

Not in Germany, Spain or Italy: volume changes how you declare, not whether you are in scope. Each country sets its own rules.

By Razvan Toma · Founder · Last checked 21 October 2026 · Sources below

• Germany: no de minimis threshold; registration and system participation apply from the first parcel.
• Spain: registration applies at any quantity; under 15 tonnes a year you file the simplified declaration.
• Italy: no minimum to be in scope; CONAI's thresholds set whether you declare monthly, quarterly or yearly.

Other countries set their own thresholds and exemptions. Our free check shows what likely applies, and we confirm each country before anything is charged.

Further detail

• Germany: a few items ↗
• Spain: a few items ↗
• Italy: a few items ↗

Sources

• EPR Germany Rep: no minimum quantity in Germany (ZSVR) ↗
• EPR Spain Rep: small quantities in Spain (MITECO) ↗
• EPR Italy Rep: small quantities in Italy (CONAI) ↗

More on this

• Does one EPR registration cover all EU countries?
• What is the difference between EPR registration, representation and reporting?
• Does the PPWR replace national packaging EPR registrations?
• Is UK packaging EPR covered by the EU rules?