EPR reporting deadlines in 2027: 50 filings, invoices and payments across 14 markets, 19 of them by 31 March

EPR reporting deadlines, market by market

Exhibit 3 lists what each scheme or authority asks of producers: the report period, the due date, how it bills and how long producers have to pay. It is built from the deadlines sections of SPI’s 14 fee-market files (data as of 14 October 2026) and brought up to date against each scheme’s own declaration guide or general terms on 4 November 2026.

Austria. ARA’s general terms tie the reporting period to the expected annual fee: annual reports below EUR 1,500, quarterly from EUR 1,500 to EUR 20,000 and monthly above EUR 20,000 (AGB IX.1). Monthly and quarterly reports are due on the 15th of the month after the period and paid on the 15th of the month after that, so a first-quarter report filed by 15 April is paid by 15 May (AGB VIII.5). Annual reporters file by 15 January and pay by 15 February, and flat-fee invoices also fall due on 15 February (AGB VIII.5, XVII.5). The year-end correction and the supplementary report under the packaging ordinance close on 15 March 2027 (AGB X.3, VIII.7).

Belgium. Fost Plus takes one annual declaration in MyFost by 28 February for the previous year’s household packaging, and members who file late risk a fine of 1% of the contribution in their previous declaration per month of delay (Fost Plus declaration page). The litter levy runs its own billing: a first advance invoice in October 2026 for half of the estimated 2026 contribution, based on the 2025 declaration, a second at the beginning of 2027, and a final settlement once the 2026 declaration is closed (Fost Plus litter levy page). Companies whose levy would be under EUR 500 get no advance invoice.

France. Citeo’s 2026 guide sets the window for declaring 2026 placements from January to the end of February, with the declaration space open from November, and a separate reuse reporting step in March that splits packaging into reusable, reused and single-use (Citeo guide 2026, p. 6). The guide applies a minimum invoice of EUR 110 but does not describe invoice timing or payment terms (p. 10).

Ireland. Repak members report twice a year: January to June by 21 August and July to December by 21 February of the following year. Repak issues two invoices a year, in January and July, each payable within 30 days, and each half-year invoice rests on the same half of the year before (Repak QF 509). Self-complying major producers follow a separate local authority timetable under S.I. 282/2014, which this piece does not cover.

Italy. CONAI declarations are periodic: quarterly in the first year of membership, then annual, quarterly or monthly according to the fee declared in the previous year for each material (CONAI declaration and payment page). Every periodic declaration is due on the 20th day of the month after the period, and the amounts are paid on receipt of CONAI’s invoices. SPI has not yet confirmed the euro thresholds for each declaration class in the 2026 guide.

Luxembourg. Valorlux takes a detailed declaration by 28 February each year for the previous year’s placings, and new members file 30 days after signing (general conditions V.3, art. 5.3). Members pay one quarter of the annual contribution each quarter, within 10 days of the advance invoice, and contributions under EUR 500 are billed once, with the fourth quarter invoice. When the declared contribution differs from the advances, Valorlux issues a complementary invoice or a credit note (art. 5.4).

Netherlands. Verpact works on two documents: an Opgaaf, the estimate that sets advance payments in the current year and must be revised if volumes move significantly, and the Aangifte, the annual declaration due before 1 April of the following year (Beleid 2026, s. 5.3). Extension requests must reach Verpact in writing at least three working days before 1 April. Payment terms sit in Article 4 and Annex 2 of the generally binding agreement rather than in the policy (s. 5.4).

Portugal and Spain. Both run a state register alongside the scheme. In Portugal, producers file annual data in APA’s SIRER register by 31 March, with a correction for the previous year and an estimate for the current one, and filing can be delegated by contract but never to a managing entity (APA UNILEX manual, p. 10). In Spain, MITECO’s producer registry takes 2026 data from 2 January to 31 March 2027, with a simplified form below 15 tonnes, and opens an ordinary change window from 1 October to 31 December each year (MITECO registry page). SPI has not yet confirmed a public annual declaration date for either Sociedade Ponto Verde (SPV) or Ecoembes.

North America. Recycle BC members file one producer report by 31 May and pay fees quarterly on 31 January, 30 April, 31 July and 31 October (Recycle BC fee schedule page). In Oregon, DEQ says supply data for the prior year is due to CAA on or before 31 May each year, so 2026 data is due on 31 May 2027 (Oregon DEQ). CAA’s 2027 schedules for Oregon and Colorado both bill annual fees in two invoices, 50% in January and 50% in July. SPI has not yet confirmed Colorado’s 2027 supply report date; a law firm summary gave 31 May 2026 for the 2026 report (Venable, April 2026).

United Kingdom and Isle of Man. Large UK producers report January to June data by 1 October and July to December data by 1 April; small producers report the whole year by 1 April, so both groups file on 1 April 2027 (GOV.UK, updated 19 August 2026). PackUK bills through the notice of liability, which sets instalment dates and amounts; the year 2 notice and its payment terms are covered in SPI News on PackUK’s November notices. Plastic Packaging Tax runs on HMRC’s quarterly return calendar. The Isle of Man applies the same tax through its own Customs and Excise Division, and SPI has not yet confirmed the Island’s return dates.

How the EPR declaration deadline for 2027 stacks up

Exhibit 2 counts, for each month of 2027, how many of the 14 markets have at least one dated producer filing, invoice or payment. The counting rule is strict: a market counts once in a month however many deadlines it has, a deadline stated only as a season does not count, and a scheme’s own reporting to its regulator does not count.

The pattern has two peaks. The first, from January to March, is the annual declaration season for the calendar-year schemes, layered on Austria and Italy’s fourth-quarter filings and the first North American invoices. The second, in July, is billing rather than data: Repak and CAA send their second invoices, Recycle BC takes its third quarterly payment, HMRC’s quarterly return falls due, and the Dutch statutory annual report closes before 1 August.

Packaging EPR payment dates: from 15 days to 151 days

Exhibit 4 measures, in calendar days, the gap between the end of a reporting period and the deadline for reporting it. It is the time a producer’s data team has to close, check and file.

Payment follows a different clock. ARA pays a month after each report, on the 15th (AGB VIII.5). Repak gives 30 days from each invoice (QF 509). Valorlux gives 10 days from each quarterly advance invoice and says all invoices are payable in cash (art. 5.3). CONAI asks for payment on receipt of its invoices. Recycle BC fixes four calendar dates. PackUK’s notice of liability sets its own instalment dates, and GOV.UK says payment is usually in instalments (GOV.UK notice of liability guidance, updated 28 October 2026).

Who files: the producer, a delegate or the scheme

The calendar also differs in who may press the button. That matters for groups that run filings from a regional hub or through a compliance service.

In Portugal, the producer must register in SIRER itself within one month of the event that triggers the duty, and the APA manual says that registration cannot be delegated. The annual data filing by 31 March can be delegated if the contract provides for it, but never to a managing entity such as SPV (APA UNILEX manual, p. 10). In Spain, MITECO’s registry takes filings from producers or their authorised representatives, and producers placing under 15 tonnes a year use a simplified form (MITECO registry page).

In the UK, size decides the rhythm: large producers, above GBP 2 million turnover and 50 tonnes, file twice a year, and small producers file once, on 1 April (SI 2024/1332, regulation 24; GOV.UK). In Ireland, Repak members file through the scheme on its half-year cycle, while self-complying major producers report to their local authority on the separate timetable in S.I. 282/2014. In Austria and Italy, the declaration class can change from one year to the next, because ARA sets it from the expected annual fee and CONAI from the fee declared in the previous year for each material (AGB IX.1; CONAI). A producer that grows past EUR 20,000 of expected ARA fees moves from four filings a year to twelve.

A framework: four EPR reporting rhythms

Every market fits one of four rhythms, defined by how often producers report and how the bill follows the data. Exhibit 5 sets them out. The rhythm decides how many filings a year a producer makes, how far invoices lag the packaging, and where a forecast error shows up.

The short-cycle schemes are the most work but the least surprise. ARA and CONAI bill roughly what a producer placed in the last month or quarter, so a volume change shows up in cash within weeks. The annual schemes are the reverse: a single filing, but advance invoices built on last year’s tonnage or a forecast, which means a fast-growing brand can be under-billed all year and then face a large complementary invoice after February. In the Netherlands, Verpact asks producers to revise the Opgaaf when volumes deviate significantly, which narrows that gap (Beleid 2026, s. 5.3).

The half-year and supply-report rhythms put the invoice furthest from the packaging. Repak bills each half on the same half of the year before; CAA bills 2027 on supply data from earlier years. For a brand that cuts packaging weight in 2026, the saving reaches the invoice in 2027 at Repak and in the North American schemes, but in the same quarter at ARA.

What each scheme says happens when a filing is late

Exhibit 6 sets out the consequences each scheme or authority states in the documents SPI read. It is a reading of published terms, not a view on enforcement, and contracts can say more.

Two features stand out. The Benelux schemes price lateness automatically, as a share of the contribution, so the cost scales with the producer’s size. ARA and Verpact go further on accuracy than on timing: ARA’s 20% penalty and Verpact’s back assessment and fine both target under-declaration, and Verpact can check a declaration for up to five years after filing (Beleid 2026, s. 6.2).

Scenarios: what a late declaration costs

The scenarios below use only the stated rules, in euros, for producers of three sizes. They are illustrations of the published formulas, not estimates of what any scheme has charged.

At the low end the Valorlux minimum of EUR 50 and the 1% rate coincide, at a contribution of EUR 5,000. Below that, the EUR 50 minimum is the effective charge. Fost Plus applies the same 1% a month to the contribution in the previous declaration, so the table reads across to Belgium for a producer with a stable contribution.

Weekend deadlines in 2027

Several 2027 deadlines fall on a Saturday or Sunday. Exhibit 9 lists them. None of the scheme documents SPI read says whether a weekend deadline moves to the next working day, so producers should plan for the earlier date.

Two more date effects matter. Easter Monday falls on 29 March 2027, so by SPI’s count the last day for a written Verpact extension request, three working days before 1 April, falls on Friday 26 March, which is Good Friday, or earlier; producers should confirm the date with Verpact. And HMRC’s rule of the last working day of the month gives Plastic Packaging Tax returns on 29 January, 30 April, 30 July and 29 October 2027 (HMRC return guidance).

The second half of 2027: invoices, true-ups and the next cycle

After the spring declarations, the calendar turns to money and to the next year’s data. July is the second peak in Exhibit 2, but it is a billing month: Repak’s July invoice, CAA’s second 50% invoices in Oregon and Colorado, Recycle BC’s payment on 31 July and the UK Plastic Packaging Tax return on 30 July. The Dutch statutory annual report under Articles 8 and 8a of the 2014 packaging decree (Besluit beheer verpakkingen 2014) also falls before 1 August, though SPI’s Netherlands file notes that it is normally discharged collectively for producers through Verpact.

The true-ups follow the declarations. Valorlux settles the gap between advances and the declared contribution through a complementary invoice or credit note, and Fost Plus settles the 2026 litter levy after the 2026 declaration closes (Valorlux art. 5.4; Fost Plus litter levy page). Neither document gives a date, so producers should expect the adjustment in the months after February rather than on a fixed day.

The autumn then opens the 2028 cycle for 2027 packaging. UK large producers file January to June 2027 data and register by 1 October 2027 (GOV.UK). Spain’s registry change window runs from 1 October to 31 December, which is the moment to fix packaging categories and scheme details before the 2027 data filing (MITECO). Citeo opens its declaration space from November for the following January to February window (Citeo guide 2026, p. 6). Austria and Italy keep their monthly and quarterly rhythm throughout, with third-quarter filings by 15 and 20 October.