EPR Fee Eco-Modulation: How Recyclability Changes Your Cost, and What Cannot Be Calculated Yet

Until now, the EPR fee depended essentially on how much the packaging you place on the market weighs. From 2030 it also depends on how recyclable it is.

This is the largest economic change in the PPWR package and, paradoxically, the one written about least precisely. The reason is simple: the criteria the calculation rests on have not been published.

This article explains the mechanism, then states plainly what can and cannot be decided today.

What eco-modulation means

The principle is direct: for the same obligation, you pay less for packaging that is easy to recycle and more for packaging that is problematic.

The mechanism is not new. Several Member States already apply forms of eco-modulation, and national schemes were required to be eco-modulated even before the regulation. What Regulation (EU) 2025/40 adds is that modulation becomes mandatory across the Union and, more importantly, that it rests on a common basis of calculation.

That common basis is the recyclability grade.

Grades A, B and C

Annex II of the regulation sets three grades, expressed as the percentage of the packaging unit that is recyclable, by weight.

Grade A starts at 95 percent. Grade B at 80 percent. Grade C at 70 percent. Below 70 percent, packaging is deemed technically non-recyclable.

Two market access thresholds sit on top of these grades. From 1 January 2030, packaging that does not fall within grades A, B or C may no longer be placed on the market. From 1 January 2038, only grades A and B remain.

The 2030 date carries a condition: it applies from 1 January 2030 or 24 months after the delegated acts enter into force, whichever is later.

The link to cost runs through the framework for modulating fees according to the grade obtained, which is to be set out in those same delegated acts.

The part most articles leave out

The grades exist in the text, but the criteria for calculating them do not exist yet.

The design for recycling methodology and the criteria for assigning grades are to be set through delegated acts the Commission must adopt by 1 January 2028 at the latest. Until they are published, no operator can grade its portfolio with certainty.

The practical consequence is important and worth stating directly. Any supplier or consultant presenting you today with a firm A, B or C classification for your packaging is selling you an estimate, not a result. It may be a useful estimate, but it is not a basis for an investment decision on tooling or line requalification.

The same applies to the fee structure, which depends on the same unpublished acts. There is no honest way today to calculate what you will pay in 2030.

What can still be decided now

Not being able to calculate does not mean not being able to decide. Three things are certain enough to act on.

First, the direction is known even if the magnitude is not. Mono-material will cost less than multilayer. Transparent, white or natural colours will cost less than colours that disrupt optical sorting. Labels and adhesives that separate during recycling will cost less than those that do not. None of these directions depends on the delegated act.

Second, grade C is not a durable solution. A format scraping through in 2030 at the 70 percent floor leaves the market in 2038. If you are investing in new packaging now, the sensible target is A or B, not the minimum threshold.

Third, the inventory can be built starting today. You need the composition of every packaging unit, by component and by weight, whatever the delegated acts eventually say. Without that inventory you cannot grade anything on the day the criteria appear, and reconstructing it retroactively takes months.

Differences between markets remain

A detail that matters for companies selling in several Member States: modulation becomes mandatory at European level, but each Member State keeps discretion over the actual proportions.

In other words, the same grade B packaging can carry different cost structures in Germany, France and Romania. Your budget model needs a per-market dimension rather than a single European figure. See what EPR across several Member States involves.

In Romania, the eco-modulation mechanism is still being operationalised across the transfer organisations and is not applied uniformly. See how packaging EPR works in Romania.

What a realistic plan looks like

This year and next are for data, not redesign. Build the packaging unit inventory with composition by component and weight. It is the one thing that does not change when the criteria arrive.

Once the delegated acts are published, grading your portfolio takes four to six weeks if the inventory already exists. Without it, months.

Reformulation decisions come after grading, but have to be taken with enough runway before 2030. Requalifying a line, shelf-life testing and redoing artwork consume between eighteen and thirty-six months in FMCG.

The correct order is inventory, then grading, then portfolio decisions. Companies trying to jump to the third stage now are spending on assumptions.

Frequently asked questions

When does eco-modulation actually start?

The modulation framework is set through delegated acts the Commission must adopt by 1 January 2028, and the grades condition market access from 1 January 2030 or 24 months after those acts enter into force, whichever is later. Until then, existing national schemes continue with their own criteria.

Can I grade my portfolio now?

You can produce an indicative estimate, useful for prioritisation. You cannot produce a certain classification, because the official methodology is unpublished.

Is grade C good enough?

For 2030, yes. For 2038, no, because grade C formats leave the market. New packaging designed today should target A or B.

How much extra will multilayer packaging cost me?

That cannot be calculated honestly today. The direction is clear, the magnitude is not. What you can do is identify now which part of the portfolio is exposed, so you know the size of the problem even without knowing its price.

Does it matter if I sell in several countries?

Yes. Modulation becomes mandatory everywhere, but the proportions stay at each Member State's discretion. Expect different cost structures across markets.

Where we come in

We build the packaging inventory with composition by component, assess which part of the portfolio is exposed to the 70 percent floor and to grade C leaving the market in 2038, and set a decision calendar tied to real requalification lead times.

We do not give you a firm A, B or C classification, because nobody can today. We give you the exposure map and the data structure that makes you ready on the day the criteria appear.

For the wider PPWR context, see the pillar article. Or book a thirty minute call.