No. These thresholds are ceilings for flat-fee coverage, rather than a required volume of activity. You pay the same amount whether you sell 50 items or 8,000 during the year: below 10,000 UVC, the Citeo flat-fee declaration costs €110 excl. VAT. The word minimum in the documents refers to the producer responsibility organisation's minimum charge, meaning its lowest charge, whatever your activity. Citeo's 2026 guide states this explicitly: a company placing zero packaging and less than 5 tonnes of paper on the market still pays the €110 excl. VAT under the contract. Above 10,000 UVC at Citeo, you move to the simplified declaration and the amount begins to depend on your actual volumes.
Read the source article: PPWR small business obligations: the micro-enterprise rule