27/08/2025

Eco-Fee-Modulation

Eco-fee modulation: What lies behind EU subsidies for packaging

Content:

 

It may sound complicated, but it can have a positive impact on your packaging licence costs in various European countries. In addition to the obvious advantages in terms of environmental protection and marketing, sustainably designed packaging is also becoming more attractive because of increasing political efforts to promote it. An important instrument in this context is eco-fee modulation, which is part of circular economy policy at both national and European level. We explain what this is all about.

 

How does packaging licensing work in Germany and Europe?

In short: The European Packaging Directive states that companies that place packaging on the market are obliged to pay for the disposal of their packaging. This is known as extended producer responsibility. The exact requirements and obligations currently vary from country to country, as each country has created its own laws to implement the European directive. However, the basic principle is the same: Those who place packaging on the market pay a fee to an EPR system, which in turn takes care of the collection, sorting and recycling of packaging waste.

In Germany, for example, you can fulfil your obligations by registering with the LUCID packaging register and licensing your packaging with a dual system (such as Interzero Recycling Alliance via Lizenzero). A detailed explanation can be found here.

 

Brief explanation: What is eco-fee modulation

In addition to the positive marketing effect that sustainably designed packaging brings, it is also rewarded at the political level. Eco-fee modulation is a tool for promoting the European circular economy. It is intended to give companies an incentive to increase their use of recyclable packaging. Some EU countries are already using it to differentiate licence or recycling costs in their respective EPR systems.

Modulation specifically aims to create incentives for the development of sustainable packaging designs by differentiating licence fees for sales packaging. In short, companies that use environmentally friendly packaging pay lower licence fees to EPR systems and thus save costs. On the other hand, packaging that does not meet the requirements of eco-modulation is taxed more heavily and is therefore more expensive. This approach is an important step towards an environmentally conscious economic policy that promotes ecological sustainability.

 

How is eco-fee modulation applied in practice?

The aim is to standardise the implementation of the eco-fee across Europe. At present, however, implementation in individual countries is still very heterogeneous.

Under the leadership of the Federal Environment Agency, Germany plans to introduce a fund into which fees and penalties will be paid. Manufacturers are obliged to check the recyclability of their packaging. They should be able to rely on a positive catalogue based on the minimum standards of the Central Agency for Packaging Registration (ZSVR).

Other countries only tax certain materials or have not yet implemented eco-fees. In France, the Netherlands, Belgium and Finland, for example, incentive models have been created so far. However, the exact design varies from country to country.

In principle, however, the recyclability of packaging on which the eco-fee is based is determined by the following criteria:

  • Sortability and separability
  • Raw material (paper, plastic, metal, glass)
  • Residual emptiness
  • Impurities in the material

 

Do you ship to different EU countries? We take care of your packaging licensing! On top of that, we can also check for you whether the design of your packaging meets the requirements of the Eco-Fee Modulation in your target markets. If the design of your packaging does not yet meet the Eco-Fee requirements, we can also help you adapt your packaging to the standards on request. Find out more now.

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