Most companies know their packaging data sits "somewhere, with someone." What they rarely work out: what that "somewhere, with someone" actually costs them. Not just in time, but in discount left on the table. Below is a worked example for a mid-sized company, using real rates and benchmarks.
The starting point: a mid-sized company
We're using the standard EU definition of a mid-sized company: 50 to 249 employees, up to €50 million in annual revenue. Say: 150 employees, and a packaging volume of roughly 120,000 kilos a year, of which 40,000 kilos is flexible plastic. Doesn't quite match your company? The maths works the same way, just adjust the figures to your own volumes.
What that time usually covers
At companies handling this in-house, it's rarely one clear task. It's an accumulation: requesting data from suppliers, converting exports into whatever format a customer or Verpact needs, chasing down missing specifications, and the annual declaration itself. In our experience, mid-sized companies quickly need at least one full-time person for this, sometimes several, spread across procurement, quality and compliance. And the real material and packaging expertise often still isn't in the room: most companies end up sourcing that externally anyway.
What that one FTE costs in euros
The average gross annual salary for a compliance officer in the Netherlands is around €71,000, with a typical range of roughly €58,000 to €91,000. Using €65,000 gross per year and the common rule of thumb of about 1.3× that amount for total employer cost (social contributions, pension, holiday pay), that one FTE costs a company around €84,500 a year. And that's the minimum: with multiple people involved, or at a larger company, this climbs quickly.
Plus the consultancy that often gets added anyway
Because the specific material and packaging expertise is often missing in-house, many companies bring in (partial) external consultancy on top. Using a realistic hourly rate of around €150 for specialised compliance or sustainability consultancy, and say one day a week of external support (roughly 400 hours a year), that adds another €60,000 a year.
Then there's the discount left unclaimed
Through tariff differentiation, plastic packaging can qualify for up to €0.60 discount per kilo, on top of a base rate of around €1.32 per kilo in 2026, by combining demonstrable use of recyclate, mono-material design, and the right colour. You only claim that discount with detailed, substantiated data per packaging item: weight, material composition, recyclate percentage. Missing that substantiation means paying the full rate, even if your packaging might otherwise have qualified.
Say half of our 40,000 kilos of plastic, 20,000 kilos, would qualify for the full discount if the data were in order: that's €12,000 a year probably going unclaimed, simply because nobody has the supporting evidence ready.
And the risk of data you can't prove
There's another risk that doesn't fit into a calculation, but counts all the same. If you claim a discount through tariff differentiation, or sign a declaration of conformity, you need to be able to substantiate it: with photos, specifications, traceable calculations. Data that was typed in from nowhere in particular, or an estimate nobody can reconstruct, is worthless under audit. That can cost you a discount you already claimed, or undermine a declaration of conformity you already issued.
Plus a risk nobody puts on the budget
According to legal advisories, fines for demonstrable PPWR non-compliance can run into the hundreds of thousands of euros for serious violations, depending on their nature and company size. Most companies aren't in that worst-case scenario, but it's the backdrop this whole calculation sits against: this isn't a matter without consequences if it goes wrong.
Added up
In this example: roughly €84,500 in internal FTE, plus roughly €60,000 in additional consultancy, plus roughly €12,000 in unclaimed discount, comes to about €156,500 a year, excluding the risk of unprovable data and excluding fine risk. And that's still the minimum scenario with exactly one FTE: with more people involved, it runs higher. Not as an absolute truth for every company, but as a method you can apply to your own volumes and salaries.
This is a worked example, not tailored advice. Rates, discount tiers and salary ranges shift every year. For the current scheme: check Verpact. For your own figures: we're happy to map that out concretely.
Curious what this means for your company, with your own volumes and your own internal time? Request the free scan, and we'll work it out for you.
