Does recyclability affect EPR fees?

Yes. Producers’ financial contributions under extended producer responsibility are modulated in line with the recyclability performance grades. Easily recyclable packaging is therefore treated more favourably than packaging that is hard to recycle. The Commission sets the precise framework by legal act.

In Germany the statutory instruments on the ecological design of participation fees are issued under section 26a of the Packaging Law Implementation Act (VerpackDG). Until the European rules take effect, they have to rely on the minimum standard of the Central Agency Packaging Register for measuring recyclability, currently the 2026 edition.

For planning this means the performance grade becomes a cost issue before it becomes a market access issue. Packaging development runs in cycles of three to five years, so the material decision for 2030 is being taken today.