In a recent conversation with AL Circle, Daniel Vaknine, Co-Founder of Gramta, explained the objectives and implementation of Extended Producer Responsibility (EPR) and the Packaging and Packaging Waste Regulation (PPWR). He discussed how the aluminium packaging industry can comply with these requirements and manage the associated costs. He also highlighted how Gramta helps aluminium packaging exporters meet their EPR reporting obligations through dedicated compliance solutions.
Daniel Vaknine is a Co-Founder of Gramta EPR software platform helping businesses navigate packaging producer responsibility requirements across Europe. His work focuses on making multi-country EPR compliance more practical, from determining producer obligations and registration requirements to packaging data, reporting and EPR costs.
AL Circle: In your view, how effective are Extended Producer Responsibility (EPR) and the Packaging and Packaging Waste Regulation (PPWR) likely to be in increasing the collection and recycling of aluminium packaging waste?
Daniel Vaknine: I think the combination can be very effective because it attacks the problem from both sides. EPR makes producers financially responsible for the packaging they place on the market, helping fund collection, sorting and recycling. PPWR increasingly focuses on whether the packaging itself is actually designed to be recyclable.
To learn the future of aluminium in the packaging industry, explore our report "ALuminium in Packaging: Consumer Trends and Market Dynamics"
That second part will become much more important. Under PPWR, packaging recyclability will be expressed through performance grades A, B and C. Grade A corresponds to at least 95 per cent recyclability by weight, B to at least 80 per cent and C to at least 70 per cent. Packaging below grade C will ultimately not be allowed on the EU market, and from 2038 the requirement tightens further to grades A or B. The framework also links these recyclability grades to future modulation of EPR fees.
For aluminium producers, this means simply saying that a package is “made from aluminium” will increasingly not be enough. The complete packaging design matters: coatings, laminates, closures, labels, other materials and whether the packaging can actually enter established collection, sorting and recycling streams.
The interesting development is therefore that recyclability becomes both an environmental issue and an economic one. Better-designed packaging should increasingly be easier to recycle, easier to place on the market and potentially cheaper from an EPR perspective.
Daniel Vaknine: Yes, in practice they can create significant market-entry friction, even though the rules themselves generally depend on where packaging is placed on the market rather than where it was manufactured.
The difficulty is the administrative and fixed-cost layer. Selling into another European country can mean another producer registration, another PRO or compliance scheme, another reporting process and potentially an authorised representative. There can also be registration charges, annual or minimum PRO fees and other fixed costs that exist regardless of whether the company sells ten packages or ten thousand.
That changes the economics for smaller exporters. If a company wants to test demand by shipping only a handful of products to a new country, the compliance cost can potentially be much larger than the actual EPR recycling fee. In some cases, it may simply not make commercial sense to enter a market for a very small number of sales.
So I would not describe EPR as intentionally protectionist. But when market access requires understanding and maintaining a separate national compliance process, it can function much like a non-tariff barrier, particularly for overseas businesses and smaller exporters.
Explore downstream aluminium suppliers, product listings and trade opportunities on AL Biz
Daniel Vaknine: The most important question is: who is legally considered the producer in the country where the packaging is placed on the market?
It is not necessarily the company that manufactured the aluminium can, tray or other packaging component. Depending on the supply chain, the obligated producer may instead be the brand owner, importer, distributor or a business selling directly across a border.
In the EU, businesses need to assess this country by country. Where they are the producer, the process will typically involve registering with the relevant national system, joining or contracting with a Producer Responsibility Organisation where required, tracking the packaging placed on that market, reporting it in the required categories and paying the corresponding EPR fees.
The reported information normally starts with packaging material and weight, but countries and schemes can require considerably more detailed classifications.
The UK has its own packaging EPR system and thresholds, so being compliant in the UK does not make a company compliant in the EU, or vice versa. The same physical package can therefore create different compliance obligations depending on where and how it is sold.
Daniel Vaknine: The EPR fee itself is only one part of the cost. Businesses can also encounter registration charges, minimum or fixed PRO fees, authorised-representative costs, external compliance support and internal administration.
Time is an important cost as well. Someone has to establish which rules apply, find the correct register and PRO, understand that country’s reporting categories, determine how the company’s packaging should be classified and then repeat the process for every additional market. Because national systems still differ substantially, this can become a surprisingly large compliance exercise for an international seller.
There are several legitimate ways to reduce the financial cost. The simplest is reducing packaging weight: where the tariff is weight-based, fewer kilograms normally mean lower EPR fees.
Packaging design can also matter. More EPR systems already reward packaging that is easier to recycle, and this will become increasingly important as PPWR’s recyclability framework develops. Better recyclability can therefore become a direct financial consideration rather than only an environmental objective.
There can also be savings in choosing the appropriate PRO where several competing systems exist. This is one reason we created Gramta’s free EPR Fee Database: published tariffs can differ between schemes, materials and packaging classifications, and businesses should be able to compare them rather than automatically using the first option they find.
Finally, accurate packaging data matters. A company should neither under-report nor pay for kilograms or packaging categories it did not actually place on that market.
Daniel Vaknine: Gramta is EPR compliance software for businesses selling packaged products across Europe. Inside the Gramta platform, we focus on two main parts: 1) country-specific compliance guidance and 2) EPR reporting calculations.
The first part is guidance. EPR is still implemented differently from country to country, so knowing that you “need EPR in Spain” or “need EPR in Germany” is not particularly useful on its own.
Gramta turns that into a personalised, step-by-step process for the markets relevant to the company. For example: first establish whether you are the producer (Gramta helps with this by letting you answer 1-3 brief questions); then complete the required registration; then join the appropriate PRO; then provide the information needed for reporting. For each step, Gramta provides the correct link so you don’t need to dive deep to find it.
The guidance can account for the company’s own markets and compliance status, rather than simply presenting a generic article about that country. The underlying Gramta system is specifically structured around registration requirements, PROs, authorised representatives, deadlines and direct links to the relevant national registration routes.
So basically, for each country, we show you the steps you specifically need to take based on your setup, and then we show you “first, go here, do this, then go there, do that”, which differs between coutnries quite a lot.
Unlock key insights from industry experts on aluminium's applications in end-use with our magazine
The second part is EPR calculation and reporting. The company provides its packaging specifications — for example the materials and weights associated with each product — and Gramta combines this with sales data to determine how much packaging has actually been placed on each market. It can then calculate the quantities that need to be reported under the relevant country’s EPR categories and maintain the underlying calculation and audit trail.
That combination is important. Knowing how to register is one problem; once registered, businesses still need to work out what numbers to report. Gramta is designed to handle both sides of that EPR compliance process.
Separately, we have made a free EU EPR Fee Database publicly available. It contains more than 3,000 sourced tariff records from more than 120 PROs and schemes across all 27 EU countries. Businesses can use it to research published EPR fees and compare schemes and packaging classifications. It is a public resource we maintain alongside the Gramta platform rather than the core product itself.
Daniel Vaknine: There is no single “European aluminium EPR fee”. The cost can depend on the country, chosen PRO, kilograms placed on the market, packaging format, household or commercial use, recyclability, reporting classification and any fixed or minimum charges.
This makes it difficult to identify one country as universally the most burdensome. A country with a high per-kilogram tariff may be expensive for a large-volume producer, while a country with substantial fixed fees may be disproportionately expensive for a small exporter. For a company with thousands of SKUs, the complexity of the reporting categories can matter as much as the tariff itself.
The differences can become surprisingly detailed. Belgium’s 2026 Fost Plus tariffs, for example, distinguish PET bottles between colourless, blue, other transparent colours and opaque PET. Even aluminium is split by thickness: aluminium of at least 50 μm and aluminium below 50 μm have very different tariffs.
The Netherlands provides another example. Plastic reporting distinguishes between rigid and flexible packaging, while its 2026 fee-modulation system can provide discounts of up to €0.60 per kilogram based on factors including recyclability, recycled content, mono-material design, colour and labels.
France works differently again: for household packaging, Citeo’s contribution model also takes the number of consumer sales units placed on the French market into account and provides different declaration routes depending on volume.
That is why comparing EPR burden using one headline €/kg figure can be misleading. The real question is: what does this specific packaging, sold in this quantity, through this business model, cost to comply with in this particular market?
Daniel Vaknine: PPWR creates a more harmonised European packaging framework, but it does not create one European EPR system.
Businesses still deal with national producer registers, different Producer Responsibility Organisations, registration processes, reporting schedules, packaging classifications, fee structures and administrative requirements.
There will also still be differences in how smaller volumes are handled. PPWR requires producer registration, while producers placing less than 10 tonnes of packaging on a market can use a simplified reporting dataset under the new framework; Member States can set a lower threshold for that simplified route where necessary. So the distinction increasingly concerns how much information must be reported, rather than simply whether a small producer has to register at all.
The practical differences between markets remain significant. One country may have one main compliance organisation while another offers several competing PROs. One may use relatively broad material categories while another asks for much more detailed information about the packaging itself.
This is one of the main problems Gramta’s EPR compliance software is designed to solve. A company should not need to become an expert in dozens of national EPR systems. Its business and packaging information can be maintained centrally, while the relevant country rules are translated into the actions and reporting requirements that apply to that company.
The regulations may remain national, but the company’s compliance process does not have to be fragmented across dozens of spreadsheets, government websites and bookmarks.
Daniel Vaknine: Yes, and I think that is one of the more interesting possibilities once the compliance data is structured properly.
The first objective for Gramta is straightforward: make packaging EPR compliance much easier. There is already enough complexity in determining where a company needs to register, what it needs to do next and what packaging quantities it needs to report.
But the same dataset has much broader potential. Once Gramta understands the company’s packaging components, materials, weights, markets and applicable EPR tariffs, opportunities for improvement will become much easier to identify.
For example, a business could assess what happens to its EPR cost if packaging weight is reduced, or compare the current packaging with a more recyclable alternative that qualifies for a more favourable EPR classification. Where a scheme uses eco-modulation, the difference can potentially be translated directly into an estimated annual saving.
That means the data collected for compliance can ultimately become useful for packaging optimisation as well: identifying expensive materials or classifications, assessing recyclability improvements, comparing alternative packaging choices and understanding the regulatory consequences before making a change.
Gramta’s longer-term ambition is therefore broader than calculating EPR reports. We want it to become a practical platform for packaging compliance and packaging decision-making - bringing together country-specific legal guidance, reporting calculations, packaging data and, increasingly, opportunities to reduce both regulatory burden and packaging costs.
We are starting with the most immediate problem, which is simply helping businesses comply correctly. But once that foundation is in place, the same information can support much better packaging decisions.
