regulation

EPR Fee Modulation: The €1.8M Annual Swing Between Best and Worst Packaging

February 20, 20267 분 소요
EPRfee modulationpackaging design

핵심 요약

EPR fee modulation now creates a €1.2-1.8M annual financial swing for typical FMCG companies. Packaging redesign pays for itself.

EPR fee modulation is changing the economics of packaging design.

Key Changes for 2026

  • France (CITEO): Malus fees for non-recyclable packaging increase 50%
  • Germany (duales System): New bonus for mono-material flexible packaging
  • Spain (Ecoembes): First-time modulation for recycled content levels
  • Italy (CONAI): Expanded tier system from 5 to 8 eco-categories

    • Financial Impact

    For a typical FMCG company with €5M annual EPR fees, the swing between best-in-class and worst-in-class packaging design is now €1.2-1.8M annually — enough to fund a complete packaging redesign program.

    데이터 출처

    CITEO, duales System, Ecoembes, CONAI, company interviews

    영향

    CFOs should model EPR fee optimization alongside procurement savings. Packaging design is now a P&L item, not just a supply chain function.