Iceland EPR
What is Iceland EPR Packaging
Iceland operates a mandatory packaging producer-responsibility system through a state-run recycling-fee model rather than the more common multi-PRO registration model used in many EU countries. The main legal basis is Act No. 162/2002 on Recycling Fees, as amended, which is administered by the Icelandic Recycling Fund (Úrvinnslusjóður / IRF). The Fund states that it executes extended producer responsibility for certain goods in Iceland and administers recycling fees under that Act.
The broader waste-policy and enforcement framework sits with the Ministry for the Environment, Energy and Climate and the Icelandic Environment and Energy Agency. Iceland’s packaging rules also reflect its obligations under the EEA Agreement, including packaging-waste targets derived from European waste legislation.
A major practical change took effect on 1 January 2023, when Iceland’s circular-economy reforms expanded the packaging fee scope. From that point, packaging made of glass, metals and wood became subject to recycling fees in addition to packaging already covered.
Does this apply to e-commerce & online sales
Yes. Iceland’s rules are triggered by placing packaged goods on the Icelandic market, especially through importation or domestic manufacture. For cross-border e-commerce, the key question is not whether the sale happens online, but who is the importer or producer for Icelandic market-entry purposes. Because recycling fees are built into the customs and tax system, distance selling into Iceland can create packaging EPR exposure where the seller or its local importer brings packaged goods into Iceland.
In practice, if a foreign seller ships goods directly into Iceland and remains the importer of record or otherwise controls importation, it should assess Icelandic recycling-fee obligations. If an Icelandic distributor or importer takes title and imports the packaged goods, that local entity will usually be the party handling the Icelandic recycling-fee compliance. This importer-based structure is a key difference from many EU producer-register systems.
Who is the “producer” under Iceland EPR?
In Iceland, the obligated party is typically the entity that introduces the packaged goods into the Icelandic market. In practical terms, that means:
- Domestic manufacturers placing packaged goods on the Icelandic market
- Importers of packaged goods into Iceland
- In some supply chains, the Icelandic entity acting as customs declarant or importer of record
The Icelandic Recycling Fund states that importers and manufacturers are responsible for arranging and/or paying for the reuse, recycling or disposal of the packaging they place on the market. That is the core EPR rule for packaging in Iceland.
Who must register for EPR packaging in Iceland
Companies that import or manufacture packaging-covered goods for the Icelandic market must ensure they are correctly set up in the Icelandic system so recycling fees can be declared and collected. The practical authorities involved are:
- Icelandic Recycling Fund (Úrvinnslusjóður / IRF) for EPR execution and fee administration
- Iceland Revenue and Customs (Skatturinn) for customs-linked recycling-fee reporting on imports
- Icelandic Environment and Energy Agency for regulatory enforcement of waste legislation
Unlike countries with a standalone packaging producer register, Iceland’s model is closely tied to the customs and fiscal system. Secondary industry guidance explains that importers register through the customs authority, domestic manufacturers through the internal revenue system, and the Recycling Fund then charges the take-back and recycling fee while handling the EPR execution side.
Iceland EPR Packaging Registration Threshold
Iceland does not appear to operate a general de minimis threshold for packaging EPR based on annual turnover or packaging tonnage. The system is built around recycling fees applying to covered packaging when goods are imported or manufactured for the domestic market, rather than only after a company exceeds a small-producer threshold.
In practical terms, foreign companies should assume that Icelandic packaging obligations can arise from the first in-scope import or first domestic placing on the market, unless a specific product category is excluded or handled under a separate mechanism such as beverage-container deposit rules.
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Packaging Covered (and Excluded)
Iceland covers packaging placed on the market by importers and manufacturers, and the fee system is now broader than plastic and paper/cardboard alone. Following the 2023 reforms, packaging made of paper/cardboard, plastic, glass, metals and wood is within the fee scope.
As a compliance framework, Iceland follows the familiar packaging logic of:
- Primary or sales packaging
- Secondary or grouped packaging
- Tertiary or transport packaging
A key exclusion in practice is single-use beverage sales packaging that falls under Iceland’s deposit-return system. The Recycling Fund’s 2026 guidance notes that where a product is in single-use beverage packaging subject to deposit, recycling fees are not charged on the sales packaging in those cases.
Producer Responsibility Organization (PRO)
Iceland does not use a conventional competitive PRO market for packaging. The central organization is the Icelandic Recycling Fund (Úrvinnslusjóður / IRF), a public body that administers recycling fees and executes extended producer responsibility for covered goods.
This makes Iceland unusual from a foreign-seller compliance perspective. Rather than selecting among several packaging PROs, businesses usually comply through the national recycling-fee structure connected to the Fund and the customs/tax administration.
EPR Registration in Iceland
The compliance process in Iceland is generally as follows:
- Determine whether your business is the Icelandic importer or domestic manufacturer of the packaged goods
- Confirm whether the packaging materials are in a covered category
- Register with Iceland Revenue and Customs if you are importing goods into Iceland
- Ensure the relevant recycling-fee codes and customs data are used in import declarations
- If manufacturing locally, ensure the business is correctly registered through the domestic tax/revenue system
- Pay the applicable recycling fees administered via the Icelandic system
- Maintain supporting records on packaging type, weight and product classification
This structure means there is often no separate “join a packaging scheme” step as seen elsewhere. Instead, correct customs classification, packaging information and fee handling are the core registration/compliance actions.
Authorized Representative
Iceland does not appear to require a packaging-specific authorized representative for foreign companies in the same way as some EU packaging regimes. The system focuses on the actual Icelandic producer/importer function rather than on a separate statutory AR appointment.
In practice, foreign companies commonly rely on one of the following:
- An Icelandic importer or distributor that assumes import compliance
- A customs representative handling customs formalities
- A local compliance advisor supporting fee classification and reporting
For foreign distance sellers, the most important issue is to identify who is the importer into Iceland. That entity is usually the compliance anchor for Icelandic packaging EPR.
What Data Must Be Reported
The Icelandic system is driven by product classification and packaging-material information. Companies should be able to document at least:
- Packaging material type
- Packaging weight
- Whether the packaging is sales, grouped or transport packaging
- Product/customs classification used for importation
- Whether the packaging is subject to the separate beverage deposit system
A 1 March 2026 update from the Recycling Fund shows how important material and weight data are: revised calculation rules apply where importers do not have confirmed information on packaging weight and type. That indicates that businesses with poor packaging data may be forced into default calculation logic rather than using verified actual data.
First Reporting Period & EPR Reporting Deadlines
Iceland does not appear to use the common half-year or annual packaging return cycle seen in many EU countries. For imports, the system is integrated into customs clearance and fee collection through the customs infrastructure, so obligations arise when goods are imported and declared.
For foreign companies, the practical “first reporting period” therefore begins with the first in-scope importation or first domestic placing on the market. Companies should not wait for a later annual registration window if they are already importing covered packaged goods into Iceland.
Labels & Marketing Claims
Iceland does not appear to have a general packaging EPR disposal label that all packaging producers must apply under the recycling-fee regime. Packaging labelling obligations in Iceland are mainly product-specific rather than general packaging-EPR instructions.
Two practical exceptions are worth noting:
- Single-use beverage containers are tied to Iceland’s deposit-return system
- Certain product categories, such as chemicals, are subject to separate Icelandic labelling rules, including implementation of CLP Regulation (EC) No 1272/2008 through Regulation No. 415/2014
Companies should also be cautious with environmental marketing claims. Iceland is part of the EEA legal environment, and recyclability or sustainability claims should be consistent with the real recyclability of the packaging and the applicable Icelandic collection route. This is especially important where deposit packaging or material-specific fee treatment applies.
EPR Eco Fees & Eco-Modulation
Iceland finances packaging EPR through recycling fees. These are material-based charges that are built into the Icelandic system and updated periodically. Official updates published by the Recycling Fund show different ISK/kg rates by packaging material. For example, from 1 January 2025, published fee changes included paper/cardboard packaging at 65 ISK/kg, wood packaging at 15 ISK/kg, and plastic packaging at 65 ISK/kg.
At present, Iceland’s model appears to be a material-based fee system rather than a mature eco-modulation regime with detailed recyclability bonuses and maluses by packaging design feature. However, the fee structure still creates cost differences between packaging materials, and the Fund can revise the fee schedule over time.
Risks, Penalties & Common Mistakes
The most common compliance mistakes in Iceland are:
- Assuming there is no packaging EPR because there is no familiar EU-style producer portal
- Treating online sales into Iceland as out of scope
- Failing to identify the Icelandic importer of record
- Using incomplete packaging-material and weight data
- Misclassifying beverage packaging that should be handled under the deposit system
- Assuming only plastic and cardboard packaging are covered after the 2023 reforms
Enforcement of waste legislation sits with the Icelandic Environment and Energy Agency. The Agency states that where corrective action is not taken, coercive measures or administrative fines can be applied. Separately, the EFTA Surveillance Authority referred Iceland to the EFTA Court over failures relating to packaging-waste rules, which shows that the area is under active regulatory scrutiny.
What E-Commerce Sellers Should Do Now
- Identify who is the importer of record for goods shipped to Iceland.
- Confirm whether your packaging materials fall within Iceland’s covered fee categories.
- Map which packaging is ordinary packaging and which falls under the beverage deposit system.
- Make sure customs declarations capture the correct recycling-fee treatment.
- Build a packaging data file with verified material and weight information.
- Review Icelandic pricing assumptions to account for ISK/kg recycling fees.
- Monitor fee updates from Úrvinnslusjóður and customs guidance from Skatturinn.
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FAQ
Is Iceland packaging EPR mandatory?- Yes. Iceland has a mandatory packaging EPR system operated through recycling fees under Act No. 162/2002 and administered by the Icelandic Recycling Fund.
- Yes, if they are the party importing packaged goods into Iceland or otherwise placing them on the Icelandic market through an Icelandic import structure.
- No general turnover or tonnage threshold is evident for packaging EPR. The system is fee-based and usually applies from the first covered import or manufacture.
- There is no general packaging-EPR disposal label under the recycling-fee regime. However, specific products may have separate labelling rules, and beverage containers may fall under Iceland’s deposit system.
- Not automatically. Icelandic packaging compliance usually follows the importer/manufacturer role, not marketplace status by itself
What is Iceland EPR Batteries
Iceland is a member of the European Economic Area (EEA) and implements EU environmental legislation through the EEA Agreement. Regulation (EU) 2023/1542 — the EU Battery Regulation — applies in Iceland through this agreement, and the EPR and waste management obligations will start on 18 August 2025.
Iceland's national EPR framework for batteries is administered through the Icelandic Recycling Fund (Úrvinnslusjóður), established under the Act on Recycling Fees (lög um úrvinnslugjald). The Fund has been operational since 2003 and covers batteries, packaging, WEEE, and other product categories. The competent authority for producer registration and enforcement is the Environment Agency of Iceland (Umhverfisstofnun).
Iceland's system operates differently from most EU Member States. When a product subject to recycling fees — including batteries — is imported into Iceland, this automatically triggers a report to the Icelandic Recycling Fund. The producer is then registered with the Environment Agency. This import-triggered mechanism means that foreign companies importing battery-containing products into Iceland become subject to EPR obligations at the point of import, rather than through a separate registration process initiated by the producer.
Does This Apply to E-Commerce & Online Sales
Yes. The EU Battery Regulation applies in Iceland through the EEA Agreement and captures distance sellers and e-commerce operators as producers. A foreign brand selling batteries or battery-containing products directly to Icelandic consumers is treated as a producer and must comply with Icelandic battery EPR obligations.
In practice, Iceland's import-triggered reporting mechanism means that when products enter Iceland through customs, recycling fee obligations are triggered automatically. Companies selling via e-commerce into Iceland should confirm with the Icelandic Recycling Fund and the Environment Agency whether direct-to-consumer online sales require a separate registration or whether the import trigger covers their compliance obligation.
Who is the "Producer" under Iceland EPR?
Under Regulation (EU) 2023/1542 and the Icelandic Act on Recycling Fees, producers and importers are responsible for the collection and achievement of utilisation norms for batteries. The definition broadly covers:
- Manufacturers established in Iceland who produce and sell batteries domestically.
- Importers bringing batteries into Iceland for the first time under their own name.
- Companies importing battery-containing products into Iceland — the act of import automatically triggers EPR obligations.
- Private label owners whose brand name appears on batteries manufactured elsewhere.
- Distance sellers and online retailers established outside Iceland who sell batteries or battery-containing products directly to Icelandic consumers.
- Economic operators who prepare batteries for re-use or repurposing — treated as producers for the second life of the battery under the EU Battery Regulation.
Who Must Register for EPR Batteries in Iceland
All producers and importers placing batteries on the Icelandic market must subscribe to the Icelandic Recycling Fund (Úrvinnslusjóður) and register with the Environment Agency of Iceland (Umhverfisstofnun).
Iceland's distinctive import-triggered mechanism means that when battery-containing products are imported, the import automatically creates a report to the Icelandic Recycling Fund. The producer is then registered at the Environment Agency. However, foreign companies selling directly to consumers without going through a traditional import process should confirm registration requirements directly with the Icelandic Recycling Fund and Environment Agency.
Collection and recycling of waste batteries is carried out by approved operators. Íslenska Gámafélagið holds a licence to collect and export batteries for recycling in Iceland, having received this licence in 2012.
Iceland EPR Battery Registration Threshold
Regulation (EU) 2023/1542 does not establish a minimum volume or turnover threshold below which producers are exempt from EPR obligations. Iceland, as an EEA member, applies the same framework. All producers and importers placing batteries on the Icelandic market must comply regardless of size or volume.
The only exemption in the Regulation concerns batteries used in military or space equipment, which are outside the scope entirely.
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Batteries Covered (and Excluded)
Regulation (EU) 2023/1542 defines five battery categories, all within scope for EPR in Iceland through the EEA Agreement:
Portable batteries Batteries under 5 kg not designed for industrial or vehicle use. Includes batteries in consumer electronics, power tools, household devices, and toys.
Light Means of Transport (LMT) batteries Batteries used in e-bikes, e-scooters, e-mopeds, and similar light electric vehicles.
Automotive (SLI) batteries Starting, lighting, and ignition batteries used in vehicles.
Industrial batteries Batteries used in industrial applications and stationary energy storage systems. Those above 2 kWh have additional requirements including battery passports from 2027.
Electric vehicle (EV) batteries Batteries used in electric cars and heavy electric vehicles.
Key exclusions:
- Batteries designed for military or space equipment — outside scope entirely
- Batteries in nuclear installations — excluded
- Second-life batteries where the operator performing re-use or repurposing becomes the new producer
Producer Responsibility Organization (PRO)
Iceland's EPR framework for batteries is managed through the Icelandic Recycling Fund (Úrvinnslusjóður), which functions as the national PRO and fee collection body for batteries and other regulated product categories. The Fund is responsible for achieving the collection and utilisation targets aligned with EU Battery Regulation requirements through the EEA Agreement.
Physical collection and recycling of waste batteries is carried out by licensed operators. Íslenska Gámafélagið operates battery collection services across Iceland, including hazardous waste reception and battery export for recycling. Batteries and other hazardous waste collected by Íslenska Gámafélagið are stored and treated in accordance with statutory requirements and operating licence conditions.
Producers subscribe to the Icelandic Recycling Fund, which uses the collected fees to finance waste battery collection, transport, and recycling operations.
EPR Registration in Iceland
The registration process for battery producers in Iceland is as follows:
- Determine whether your business qualifies as a producer or importer placing batteries on the Icelandic market.
- If established outside Iceland, confirm whether your sales model triggers the import-based reporting mechanism automatically, or whether separate registration is required.
- Subscribe to the Icelandic Recycling Fund (Úrvinnslusjóður) — the Fund manages fee collection for batteries.
- Register with the Environment Agency of Iceland (Umhverfisstofnun) as a battery producer.
- Pay recycling fees to the Icelandic Recycling Fund based on the weight and type of batteries placed on the Icelandic market.
- Ensure compliance with collection and utilisation norms aligned with EU Battery Regulation targets.
Foreign companies selling directly to Icelandic consumers via e-commerce should contact the Icelandic Recycling Fund and Environment Agency directly to confirm the applicable registration procedure for their specific sales model.
Authorized Representative
Regulation (EU) 2023/1542 requires that producers not established in the relevant country appoint an authorized representative to fulfil EPR obligations. As an EEA member state, Iceland applies this requirement.
Foreign companies without an Icelandic establishment should confirm the specific authorized representative requirements with the Environment Agency of Iceland, as Iceland's import-triggered system may operate differently from the standard EU AR appointment model.
Important development: In December 2025, the European Commission proposed suspending the authorized representative requirement for EU/EEA-established companies until 2035. This proposal has not been formally adopted as of May 2026. For non-EEA producers, the requirement is not affected.
What Data Must Be Reported
Producers subscribed to the Icelandic Recycling Fund must report data on batteries placed on the Icelandic market. Iceland's system is built around the import trigger — data is generated at the point of import and flows to the Icelandic Recycling Fund. Producers should report:
- Total weight (kilograms) of batteries placed on the Icelandic market, broken down by battery category
- Battery chemistry type where relevant to fee calculations
- Collection and recycling performance data aligned with EU Battery Regulation targets
Specific reporting requirements and timelines should be confirmed with the Icelandic Recycling Fund at the time of subscription.
First Reporting Period & EPR Reporting Deadlines
Battery EPR has been in place in Iceland since the early 2000s under the former EU Batteries Directive, incorporated through the EEA Agreement. The new EU Battery Regulation obligations took effect from 18 August 2025 through the EEA Agreement. Key dates:
- 18 August 2025: EU Battery Regulation EPR obligations take full effect in Iceland through the EEA Agreement.
- 18 February 2027: Battery passports mandatory for industrial batteries (>2 kWh) and EV batteries.
- 18 August 2027: Due diligence obligations in force (delayed under Omnibus IV).
Annual reporting deadlines and fee payment schedules are set by the Icelandic Recycling Fund. Producers should confirm specific timelines directly with the Fund.
Labels & Marketing Claims
Crossed-out wheeled bin symbol From 18 August 2025, all batteries must display the separate collection symbol covering at least 3% of the area of the largest side of the battery, up to a maximum of 5 × 5 cm.
Chemical symbols Batteries containing more than 0.002% cadmium must be marked Cd. Batteries containing more than 0.004% lead must be marked Pb.
Capacity marking Portable and rechargeable batteries must display capacity information.
QR code From 18 August 2026, all batteries must carry a QR code. For LMT, industrial (>2 kWh), and EV batteries, this links to the Digital Battery Passport from 18 February 2027.
CE marking Mandatory from 18 August 2024.
Language requirements Consumer-facing information on batteries sold in Iceland should be provided in Icelandic where required under Icelandic consumer protection law.
Environmental claims Environmental and sustainability claims on products and marketing materials must comply with Icelandic consumer protection law. EEA-incorporated EU green claims legislation will also apply as it takes effect.
EPR Eco Fees & Eco-Modulation
The Icelandic Recycling Fund sets recycling fees for batteries based on the weight and category of batteries placed on the Icelandic market. The fees collected are used to subsidise end-of-life battery collection, transport, and recycling — costs that exceed the market value of recovered battery materials.
Specific fee rates should be confirmed directly with the Icelandic Recycling Fund at the time of subscription, as rates are subject to periodic review.
Under Regulation (EU) 2023/1542, eco-modulation — adjusting contributions based on battery environmental performance — is required. Iceland's specific eco-modulation framework under the new Regulation has not been separately published as of May 2026.
Risks, Penalties & Common Mistakes
- Assuming Iceland's import-triggered system means no action is required. The automatic import trigger generates a report and registration, but producers are still responsible for ensuring their compliance is properly established with both the Icelandic Recycling Fund and the Environment Agency. E-commerce sellers without a traditional import process should not assume the trigger applies automatically to their sales.
- Failing to subscribe to the Icelandic Recycling Fund. Subscription to the Fund and payment of recycling fees is mandatory for all battery producers and importers. Operating without Fund subscription is a breach of the Act on Recycling Fees.
- Assuming EU registration covers Iceland. Iceland is not an EU Member State. Battery EPR registration in an EU country does not fulfil Icelandic obligations. Iceland operates its own national system through the EEA Agreement.
- Missing labelling requirements. The crossed-out wheeled bin symbol and CE marking are mandatory from August 2025.
- Missing the QR code deadline of August 2026. Companies should begin QR code implementation well in advance.
What E-Commerce Sellers Should Do Now
- Confirm whether your products contain batteries and whether they are being sold to Icelandic consumers.
- Contact the Icelandic Recycling Fund (Úrvinnslusjóður) to confirm subscription requirements and fee rates for batteries in your category.
- Register with the Environment Agency of Iceland (Umhverfisstofnun) as a battery producer.
- If established outside Iceland, confirm whether an authorized representative is required for your specific sales model with the Environment Agency.
- Verify that all batteries carry the crossed-out wheeled bin symbol, CE marking, and capacity information as required from August 2025.
- Plan for the QR code requirement by August 2026 and the Digital Battery Passport for industrial and EV batteries by February 2027.
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FAQ
Is battery EPR mandatory in Iceland?
- Yes. Battery EPR has been mandatory in Iceland since the early 2000s under EU legislation incorporated through the EEA Agreement. From 18 August 2025, the new EU Battery Regulation (2023/1542) applies in Iceland through the EEA Agreement. All producers and importers of batteries must subscribe to the Icelandic Recycling Fund and register with the Environment Agency of Iceland.
Do foreign brands selling online into Iceland need to register?
- Yes. Foreign companies placing batteries on the Icelandic market are subject to EPR obligations. Iceland's import-triggered system automatically creates a report when battery-containing products are imported, but foreign brands selling directly to consumers via e-commerce should confirm with the Icelandic Recycling Fund and Environment Agency whether their specific sales model requires a separate registration process.
How does Iceland's import-triggered system work?
- In Iceland, when a product subject to recycling fees — including batteries — is imported, the import automatically triggers a report to the Icelandic Recycling Fund and registration at the Environment Agency. This differs from most EU Member States where producers must initiate registration themselves. However, this mechanism primarily applies to traditional import channels; e-commerce sellers should confirm coverage with the Fund directly.
Is there a minimum volume threshold below which registration is not required?
- No. The EU Battery Regulation does not establish a minimum volume or turnover exemption for EPR obligations. Iceland applies the same framework through the EEA Agreement. All producers placing batteries on the Icelandic market must comply regardless of size.
Does EU battery EPR registration cover Iceland?
- No. Iceland is not an EU Member State. Battery EPR registration in an EU country does not fulfil Icelandic obligations. Iceland operates its own national EPR system through the Icelandic Recycling Fund, administered under the EEA Agreement. Separate registration and fee payment in Iceland is required.
Textile EPR law in Iceland: None enacted
Iceland is not among the countries with enacted textile EPR legislation.
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