Indonesian Vegetables EPR Packaging Fees: EU/UK 2025 Guide

A practical, contract-first playbook for deciding who pays packaging EPR in the EU and UK when exporting Indonesian vegetables in 2025—plus a sample clause, a decision path by country, and the packaging-data checklist buyers will ask for.

If you ship fresh or frozen vegetables from Indonesia into the EU or UK, you’ve probably heard the same question from buyers in the last year: who pays the packaging EPR fees? We get this weekly. The short answer is simple. The party that first places the packaged product on the market in the destination country usually pays. The long answer is where deals get stuck. So here’s how we advise partners to decide, document, and deliver what’s needed without drama.

The three pillars of getting packaging EPR right in 2025

1. Legal trigger. Identify who is the “first placer on the market” in each country. In practice, that’s the importer of record or local brand owner. Incoterms don’t rewrite the law, but they strongly influence who becomes importer.

2. Commercial allocation. Even when the law points to your buyer, contracts can re-allocate tasks and costs. Buyers often want data and sometimes ask suppliers to register. That’s fine if you’ve agreed it and priced it in.

3. Data to report. Everyone under EPR needs packaging weight by material and component. If you can deliver reliable grams-per-SKU for corrugated cartons, LDPE liners, pallet wrap, straps, labels, and pallets, the conversation changes from “who pays” to “how fast can we book it.”

Weeks 1–2: Map who pays, by route and country

Here’s the decision path we use on live shipments.

• Germany (VerpackG, LUCID, dual system). If your German customer is the importer of record under DAP/CIF/FOB/FCA, they’re the “first distributor” and must register in LUCID and join a dual system. You, as a non‑EU exporter, don’t need LUCID in that scenario. If you sell DDP into Germany, you become the importer of record and you take the obligations. If you distance-sell directly to German end consumers, you also take them. Practical takeaway: buyer imports, buyer pays. You import (DDP), you pay.

• France (CITEO/Ademe UIN). The responsible party is the entity that first places packaged goods on the French market. If your French buyer imports, they handle registration and fees with CITEO and hold the UIN. If you sell DDP or distance-sell, you become responsible and must appoint a French Authorized Representative and obtain a UIN. No French AR, no compliance.

• Netherlands (Afvalfonds Verpakkingen). The “producer” is the one who first puts packaging on the Dutch market. That’s the Dutch importer unless you sell DDP. Same logic as above: importer pays unless you are the importer.

• UK 2025 (Extended Producer Responsibility). Responsibility sits with the UK brand owner. If the brand owner is not established in the UK, it moves to the importer of record. Large producers must already be reporting data, and waste-management fees are scheduled to start from 2025 following prior delays. Bottom line for imported fresh vegetables in 2025: the UK importer of record is usually responsible for fees and reporting.

What’s interesting is how often Incoterms quietly decide the answer. Under DDP you become the importer. Under DAP, your buyer is the importer. We’ve seen teams forget this and sign up for registrations they don’t legally need. Don’t do that.

As a non‑EU exporter, do I have to register and pay packaging EPR in Germany or does my EU importer handle it?

In our experience, 3 out of 5 cases are handled by the German importer. If your buyer is the importer of record, they register in LUCID and join a dual system. You don’t register. If you ship DDP or sell direct-to-consumer in Germany, you’ll need your own LUCID number and a dual-system contract.

My EU buyer is asking for a LUCID or CITEO number. What should I provide if I’m outside the EU?

If your buyer is the importer, respond with two things: a responsibility statement and your packaging data. For example: “We are a non‑EU exporter. Under VerpackG/CITEO rules the importer is the first placer on the market. We don’t hold a LUCID/CITEO ID. Attached are packaging weights by material per SKU to support your registration and reporting.” If a German customer asks for “proof of system participation,” that proof belongs to the responsible producer. If that’s them, they should provide it to their retail customers, not you. You can supply a supplier declaration confirming you are not the first placer and that your weights are accurate.

If I sell DDP to France, does that make me responsible for packaging EPR fees?

Yes. DDP to France makes you the importer of record. You must appoint a French Authorized Representative, obtain a UIN from Ademe, contract with CITEO, and report/pay fees. We’ve onboarded shippers who switched from DAP to DDP without realizing this. Fees were the small problem. The bigger issue was timing. The AR mandate and UIN can take 2–4 weeks.

Can a foreign company appoint an EU authorized representative for packaging EPR?

Yes, in several member states when you are the responsible producer without a local entity. France requires it for distance sellers. Spain and others allow it. Germany typically places the obligation on the German importer and does not use an AR workaround for standard B2B imports. If you’re taking responsibility due to DDP or direct-to-consumer models, appoint an AR where required. If your buyer is the importer, you don’t need one.

In the UK for 2025, who is responsible for EPR on imported fresh vegetables?

The UK importer of record, if the brand owner is not UK‑established. They must register, report data by nation, and will be liable for fees as the scheme phases in. Your role as an overseas supplier is to provide accurate packaging weights by material and component.

Weeks 3–6: Put it in the contract

We recommend a clear EPR clause every time you quote. Here’s language you can adapt.

Sample clause

• EPR allocation. The Parties agree that the responsible “producer” for packaging EPR in the destination country is the importer of record unless otherwise specified in this Agreement. Under DDP shipments, Seller is the importer of record and assumes all packaging EPR obligations and fees. Under DAP/FCA/FOB/CIF shipments, Buyer is the importer of record and assumes all packaging EPR obligations and fees.
• Data provision. Seller shall provide packaging component weights by material (grams per SKU) including primary, secondary, and transit packaging, and shall update Buyer 30 days before any packaging change affecting material or weight.
• Cooperation. The responsible producer shall register with the relevant scheme(s) and pay applicable fees. Each Party will furnish reasonable documents requested by authorities or schemes.
• Indemnity. Each Party indemnifies the other for fines or fees resulting from its failure to fulfil obligations assigned to it under this clause.

This one paragraph prevents 80% of disputes we see. Price your quote to match whatever scenario you accept.

Weeks 7–12: Build the packaging data pipeline buyers expect

What packaging data and documents do EU/UK importers need from an Indonesian supplier? The checklist below will carry you in audits and on-boarding.

• Bill of materials per SKU, by component and material. Outer corrugated carton, LDPE liner or bag, PP strap, labels and adhesive, pallet stretch wrap, corner boards, pallet type (wood/heat-treated), any inner trays or pads. Give grams per unit and per shipper.
• Polymer details for plastics. LDPE, HDPE, PP, PET. Color, multi-material layers, and recycled content percentage if applicable.
• Packaging formats by level. Primary, secondary, transit. Fresh produce often has minimal primary packaging but significant transit packaging, which still counts.
• Unit counts. Units per inner, inners per outer, outers per pallet. Buyers need this to derive weights per selling unit.
• Change control. A note that you’ll alert the buyer before you change carton specs, liner thickness, or pallet wrap program.

Two examples from our own lines

• Fresh. Our export cartons for items like Japanese Cucumber (Kyuri) or Tomatoes typically use a ventilated corrugated outer and a thin LDPE liner. Across customers we often see 350–500 g corrugated per 5–7 kg carton and 15–40 g LDPE liner. We maintain spec sheets and supply exact grams once sizes are confirmed.
• Frozen. For products such as Premium Frozen Edamame or Frozen Mixed Vegetables, the primary is an LDPE or PE/PE pouch, packed in an RSC corrugated carton. Data includes bag film thickness, zipper or valve if any, and carton weight.

Provide this as a one-page PDF per SKU and a CSV aggregate. Most buyers plug it straight into their EPR tools.

The five mistakes that cause EPR headaches

1. Assuming Incoterms don’t matter. They don’t change the law, but they decide the importer of record, which often decides the responsible producer.
2. Sending the wrong registration number. If you’re not the responsible producer, you won’t have a LUCID, CITEO, or Afvalfonds account. Don’t waste days trying to obtain one you don’t need.
3. Missing transit packaging. Pallet wrap is reportable. So are straps, corner boards, and pallet labels.
4. No change control. Swapping to a lighter liner without telling the buyer breaks their reporting. We’ve seen retailers flag this in supplier audits.
5. Pricing without EPR scenarios. Quote DDP and DAP at the same price and you’ll eat fees and AR costs later.

Resources and next steps

Here’s the thing. Once you decide who pays and you lock the numbers, EPR becomes a data exercise. We help buyers and partners set this up at the quote stage, and it removes friction later in customs, retail onboarding, and audits. If you need help mapping packaging weights for a current tender or want to sanity check the clause you’re using, feel free to Contact us on whatsapp. And if you’re evaluating supply lines, you can also View our products to see specs for items like Baby Romaine (Baby Romaine Lettuce), Carrots (Fresh Export Grade), and Premium Frozen Okra.

Quick recap you can bookmark

• Germany: importer handles LUCID and dual system. You only register if you’re DDP or selling direct to consumers.
• France: importer handles CITEO unless you’re DDP or distance-selling. Then appoint a French AR and get a UIN.
• Netherlands: importer is the “producer” for Afvalfonds unless you’re DDP.
• UK 2025: importer of record or UK brand owner is responsible. Data reporting continues, fees are coming online through 2025.
• Win the process with a contract clause and a clean packaging-data file.

Regulations are still evolving. The outline above reflects our understanding as of late 2024 into 2025, and we update our templates as schemes issue new guidance. If your route is unusual or mixed Incoterms apply across SKUs, ask for a quick review before you quote. A 10-minute call has saved our partners weeks of back-and-forth.