Following the increase of the Extended Producer Responsibility (EPR) fee rates on 1 October 2025, uncertainty emerged over whether the EPR fee rates will be further increased or whether they will be subject to indexation.
The State Secretary of Energy's decree regarding 2026 EPR fee rates shows no increase in rates. Furthermore, due to the timely publication of the decree, indexation with inflation has been avoided.
Based on the current legal framework, the EPR fee rates that came into effect on 1 October 2025 will remain applicable from 1 January 2026.
It is important to note that additional EPR fee codes have been introduced for certain battery types. These new codes will require administrative tasks for the fulfilment of the respective reporting obligations.
Although the EPR fee rates will not change for 2026, reviewing existing EPR processes is still advised due to the pressure on supply chains and the introduction of various EU ESG-themed obligations, such as the Carbon Border Adjustment Mechanism (CBAM). Reevaluating these processes can ensure that market participants can leverage potential savings opportunities.
KPMG's experts are ready to assist with identifying EPR-related obligations, fulfilling relevant reporting obligations, and identifying simplifications and exemptions.
