EPR Fees
Interviewer:
When will the amount of the Extended Producer Responsibility fee be defined, and how significant could the impact be?
Expert:
EPR fees will continue to be set within national EPR systems, so the exact amounts will not be fixed centrally at EU level.
What PPWR does is harmonise certain administrative EPR obligations, such as registration, reporting deadlines and data granularity. It also harmonises the framework for eco-modulation based on recyclability performance grades. The first reporting under the new harmonised register rules is expected to be established by 2028.
The financial impact may be significant, depending on the packaging material, weight, recyclability grade and any additional national criteria such as recycled content or reusability. For MM, the key is to design packaging that performs well under future recyclability and EPR eco-modulation criteria.
Harmonisation of EPR Fees
Interviewer:
Will these EPR fees be harmonised across Europe?
Expert:
Not fully. PPWR harmonises important elements, especially producer registration, reporting obligations, the definition of who the "producer" is, and the criteria for EPR eco-modulation.
However, Member States will still have flexibility to organise their national EPR systems and waste management structures. Therefore, the calculation logic will become more harmonised, but actual fee levels are still expected to differ between Member States.
Recyclability Score
Interviewer:
Regarding the recyclability score as part of Design for Recycling-who determines the final score? Will there be differences between EU countries?
Expert:
The Design for Recycling criteria will be defined by the European Commission, with adoption expected by 2028, followed by a transition period for compliance. The process involves expert committees from Member States and consultation with industry stakeholders. Both the Commission and the European Parliament must approve the delegated act, ensuring alignment across the EU.
The objective is to create a harmonised EU framework. The final recyclability performance grade will therefore be based on EU-level criteria, not on separate national scoring systems.
The transition towards the PPWR framework is expected to reshape how organisations approach packaging design, compliance and long-term planning. While several implementing measures are still to come, understanding the regulatory direction today can help businesses assess potential impacts and prepare their packaging portfolios for future requirements. As Markus Müller highlights, early preparation, collaboration and a clear understanding of evolving sustainability regulations can help organisations navigate change with greater confidence.