How does EPR reporting work, and who files the declarations?

Eldris files your EPR declarations, and that is included in each registration's price, nil returns included. You send the weight and number of units you placed on each market for each period, by material where the scheme asks for it. Eldris then submits them. Lithuania is the exception: its reporting platform and reports are billed at cost, as its lines show. Reporting follows registration: under Regulation (EU) 2025/40 (the PPWR), Article 44(2), a producer registers in each country where it first makes packaging available. Each country then asks what was placed there.

What goes into an EPR declaration

A declaration states what you placed on one country's market in one period. It gives the weight and the number of units, by material where the scheme asks for it. Packaging is declared in kilograms by material, electrical equipment in pieces or kilograms by category, and batteries by chemistry and weight.

The detail depends on the scheme. Where a packaging scheme splits household packaging from commercial packaging, your figures are split the same way. Batteries are declared by type and chemistry, such as portable or industrial, lithium-ion or alkaline. Hungary classifies every product by a KF code derived from its customs tariff code. Eldris therefore needs the 8-digit customs (CN) code of each product you sell there. The figures matter beyond the filing itself. Most scheme charges are calculated on the quantities you declare, so the declaration is also the basis of what the scheme invoices. At registration, estimates are acceptable: the first filing can rest on your expected annual volumes in units and weight. Actual figures replace them in the periodic reporting cycles, once you have sales data from each marketplace. For how packaging volumes are worked out market by market, read the guide to packaging EPR across EU markets.

Who files the declarations

Eldris files them in every country where it registers you, and the filing is part of each registration's price. In Germany a producer can no longer file its own declarations, so the representative submits them.

The representative is a legal role. A seller established outside a country appoints an authorised representative there for packaging, under Regulation (EU) 2025/40, Article 45(3). The same applies to batteries, under Regulation (EU) 2023/1542, Article 56(3). For electronics, a seller not registered there itself registers through an authorised representative, under Directive 2012/19/EU, Article 16(1). Eldris appoints the representative wherever the law requires one, under the power of attorney you sign at onboarding. That document names EldrisAi OÜ as your single point of contact. Outside Germany, Eldris files for you as well, because the terms include the declarations in each registration's price. From registration onwards, Eldris handles the renewals, the declarations and the correspondence with the authorities. Nil returns are declarations too. Where a scheme expects a declaration for a period with no sales, Eldris files the nil return, and that filing is included.

What Eldris needs from you, and when

Each period, you send the weight and number of units you placed on each market, by material where the scheme asks. Eldris then files the declarations, as often as each scheme sets.

The price list names the cycle only for some lines. The Hungary packaging line includes KF-code classification and all four quarterly filings, including nil returns. The Sweden packaging line includes all four quarterly filings, and the Spain electronics line includes the RII-AEE registration with quarterly filings. The United Kingdom packaging line covers producer registration and annual declarations. Elsewhere, declarations fall per period, as the scheme sets. Weights and material data come from your own records: Eldris does not test products or packaging. Send your figures country by country rather than as one European total, because each declaration covers one market. If a country had no sales in a period, say so, and Eldris files the nil return. The steps from payment to registration numbers, and the reporting that follows, are set out on the how it works page.

What reporting costs, and the Lithuania exception

Filing is included. Under section 5.1 of the terms, annual declarations and reporting, nil returns included, are part of each registration's price. In Lithuania, reporting fees charged by third parties are passed through at cost.

Lithuania's lines show where that cost sits. The packaging line lists a reporting platform, its initial setup and a charge per report as third-party fees billed at cost. The electronics and battery lines list a charge per report in the same way. The figures sit against each Lithuania line on the pricing page, and Eldris invoices them when the third party bills them, never marked up. One further cost follows from what you declare, and it is not the filing. The scheme's contributions are mostly calculated on the declared quantities. A line may include an allowance, and contributions above it are passed through at cost. Each scheme's published tariff, and an estimator that applies it to your quantities, are on the scheme and authority fees page. Third-party fees are not part of the Eldris price, and they are the same whichever provider you use. The wording that governs all of this is in the terms.

When figures are late, missing or from a past period

Late or missing figures hold up the declaration, because Eldris files from the figures you send. Sales from before your registration are not part of the included declarations, so raise them before you pay.

Eldris can file only what it has. If figures arrive late, the declaration waits for them; if a market had no sales, telling Eldris lets the nil return go in. Where you only have estimates, say so. Estimates are acceptable for the initial registration, but the periodic reporting cycles need actual figures, once you have sales data from each marketplace. Scheme contributions calculated on declared quantities then follow those actual figures, passed through at cost. Sales made before Eldris registered you are a separate matter. The included declarations are those for the registration's year, which runs 12 months from the date each country confirms it. Tell Eldris about earlier sales before you pay, by replying to your quote. Eldris does not promise that a registration covers earlier periods. How the year starts is explained in the guide to registration times. This question also sits with the others sellers ask on the questions page.

Frequently asked questions

Can I file the declarations myself?

Not in Germany, where producer-filed declarations are no longer accepted and the representative submits them. Elsewhere there is no need: the filing is included in each registration's price, and Eldris files from the figures you send.

How often must I send my quantities?

Per period, as each scheme sets. The price list names the cycle for some lines. Packaging in Hungary and Sweden has all four quarterly filings, electronics in Spain quarterly filings, and UK packaging annual declarations.

In what format do I send the figures?

Send one set of figures per country, because each declaration covers one market. Each set gives the weight and number of units placed on that market in the period, by material where the scheme asks. Weights and material data come from your own records.

What if I sold nothing in a country during a period?

Tell Eldris, and it files a nil return. The terms include nil returns in each registration's price, so the filing is not charged separately. Lithuania's third-party reporting fees are the one exception, passed through at cost.

What if my estimate at registration was wrong?

Estimates are acceptable for the initial registration. Actual figures are reported in the periodic reporting cycles, and scheme contributions calculated on declared quantities follow those figures, passed through at cost.

Can Eldris report sales made before I registered?

Not within a new registration: the included declarations cover the registration's own year. Tell Eldris about earlier sales before you pay, by replying to your quote. Eldris does not promise that a registration covers earlier periods.