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How are EPR fees calculated? Schemes set rates in 12 of 14 markets, and regulators mostly approve the method

EPR fees are calculated by taking the net cost of collecting, sorting and recycling each packaging material, after material sales revenue, adding administration and other required costs, and dividing by the tonnes producers report; in 12 of the 14 fee markets Strategic Packaging Insights (SPI) tracks, the producer scheme sets the schedule, and only the UK and the Isle of Man have a public body fix the charge itself.

By the SPI teamPublished Updated 20 min readFigures as of 3 Nov 2026

Who sets EPR fees, in three numbers

12 of 14

Markets where the producer scheme sets the schedule

The UK (PackUK) and the Isle of Man (Treasury, by statute) are the exceptions

SPI analysis, Exhibit 2

7 of 14

Markets with a formal check before or as fees take effect

Belgium, Austria, France and Ireland add ex ante checks; Oregon, Colorado and B.C. approve the plan that holds the method

SPI analysis, Exhibit 5

29 to 129 days

Notice before a new fee applied, 2026 cycle

Isle of Man rate (3 Mar to 1 Apr 2026) to CONAI plastic (25 May to 1 Oct 2026)

SPI calculation, Exhibit 8

Source: SPI analysis of governing laws, licences and scheme documents for 14 fee markets, consulted 14 Oct to 3 Nov 2026 (SPI summary), checked 13 Oct 2026.

Counts are SPI's classification (Exhibit 2). Lead times are days from the public release SPI could date to the first day the new fee applied.

SPI read the fee-setting rules in the governing laws, licences and scheme documents of all 14 markets in its EPR & Plastic Tax Calculator. The formula is broadly shared; what differs is who signs the schedule off, what the law says it may cover and how much notice producers get, from 29 days on the Isle of Man to 129 days for CONAI’s October 2026 plastic change.

Exhibit 1A public body sets the fee in only 2 of 14 markets; in 5 the scheme's own board or assembly has the last word Unit: number of markets
Exhibit 1. A public body sets the fee in only 2 of 14 markets; in 5 the scheme's own board or assembly has the last word4 bars. Largest: Scheme sets inside its licence or agreement (Italy, Netherlands, Spain, Portugal, Luxembourg), 5.State sets the charge (UK, Isle ofMan)State sets the charge (UK, Isle of Man): 2 number of markets2Regulator approves the plan andmethod; scheme sets yearly fees(Oregon, Colorado, British Columbia)Regulator approves the plan and method; scheme sets yearly fees (Oregon, Colorado, British Columbia): 3 number of markets3Scheme sets, with an ex ante publiccheck (Belgium, Austria, France,Ireland)Scheme sets, with an ex ante public check (Belgium, Austria, France, Ireland): 4 number of markets4Scheme sets inside its licence oragreement (Italy, Netherlands, Spain,Portugal, Luxembourg)Scheme sets inside its licence or agreement (Italy, Netherlands, Spain, Portugal, Luxembourg): 5 number of markets5Exhibit 1. A public body sets the fee in only 2 of 14 markets; in 5 the scheme's own board or assembly has the last word4 bars. Largest: Scheme sets inside its licence or agreement (Italy, Netherlands, Spain, Portugal, Luxembourg), 5.State sets the charge (UK, Isle of Man)State sets the charge (UK, Isle of Man): 2 number of markets2Regulator approves the plan and method; scheme setsyearly fees (Oregon, Colorado, British Columbia)Regulator approves the plan and method; scheme sets yearly fees (Oregon, Colorado, British Columbia): 3 number of markets3Scheme sets, with an ex ante public check (Belgium,Austria, France, Ireland)Scheme sets, with an ex ante public check (Belgium, Austria, France, Ireland): 4 number of markets4Scheme sets inside its licence or agreement (Italy,Netherlands, Spain, Portugal, Luxembourg)Scheme sets inside its licence or agreement (Italy, Netherlands, Spain, Portugal, Luxembourg): 5 number of markets5

Source: SPI analysis of governing laws, licences and scheme documents for 14 fee markets (Exhibit 2), checked 13 Oct 2026.

Each market is counted once, in the model that describes who has the last word on the annual schedule. The Isle of Man figure is a plastic packaging tax aligned by statute with the UK rate, not an EPR fee.

Show the data
Exhibit 1. A public body sets the fee in only 2 of 14 markets; in 5 the scheme's own board or assembly has the last word (number of markets)
Governance modelMarkets (number of markets)
State sets the charge (UK, Isle of Man)2
Regulator approves the plan and method; scheme sets yearly fees (Oregon, Colorado, British Columbia)3
Scheme sets, with an ex ante public check (Belgium, Austria, France, Ireland)4
Scheme sets inside its licence or agreement (Italy, Netherlands, Spain, Portugal, Luxembourg)5

Executive summary

Most published guides to extended producer responsibility fees list rates. This piece looks one step earlier, at the machinery that produces them: the formula, the people who sign it off and the calendar they work to. It covers all 14 markets in the SPI EPR & Plastic Tax Calculator: Austria, Belgium, British Columbia, Colorado, France, Ireland, the Isle of Man, Italy, Luxembourg, the Netherlands, Oregon, Portugal, Spain and the United Kingdom. Rates themselves are in SPI’s per-tonne comparison and are not repeated here.

The formula is close to universal. A scheme budgets the net cost of each material stream, meaning collection, sorting and recycling less the money it gets for the bales, adds its administration and any reserve, and divides by the tonnes its members report. Fost Plus calls this the real cost deficit per material; PackUK divides net council cost by household tonnage; Circular Action Alliance (CAA) credits commodity revenue to the materials that earned it; Austria’s packaging ordinance requires a traceable cost calculation spread over the mass in each tariff category (Exhibit 4).

Governance is where markets split. SPI groups them into four models (Exhibit 5). In two, the state sets the charge. In three North American markets, the regulator approves a programme plan that fixes the method and the scheme sets each year’s rates within it. In four European markets, the scheme sets rates but a public body sees them first: Belgium’s Interregional Packaging Commission, Austria’s environment ministry with an auditor’s opinion, France’s stakeholder committee and ministry, and Ireland’s Minister. In the other five, the scheme’s own board or general assembly has the last word, inside the limits of its licence.

Timing is the practical risk. Producers had 64 days’ notice of Oregon’s 2026 schedule and 129 days of CONAI’s October 2026 plastic change, while UK producers learn their year 2 bill in November 2026, eight months into the year it covers (Exhibit 8). Several schemes also reserve the right to change fees mid-year.

For leaders, the message is to manage fee governance like a supplier contract: know who decides, when, on what data, and where your trade body can be heard before the number is final.

Key findings

  1. In 12 of 14 markets the producer scheme sets the annual fee schedule; only PackUK in the UK and the Isle of Man Treasury, which by statute follows the UK plastic packaging tax rate, fix the charge as public bodies (SPI analysis, Exhibit 2).
  2. All six schemes whose method SPI could read in full (Exhibit 4) price fees from a net cost per material divided by reported tonnage; Colorado’s law adds two hard limits, 100% of service providers’ net recycling services costs reimbursed and no more than 5% of dues spent on administration (C.R.S. 25-17-705(4)(i) and (j)).
  3. Four European schemes face an ex ante public check: Fost Plus sends rates and method to the Interregional Packaging Commission after its June board, ARA must notify planned tariff changes to the ministry with an auditor’s opinion, Citeo needs a published stakeholder committee opinion, and Repak’s fee structure must satisfy Ireland’s Minister.
  4. France is the one market where the state also writes part of the modulation itself: an arrêté of 5 September 2025, issued after a commission opinion of 13 March 2025 and a public consultation, fixes recycled-plastic primes for packaging from 1 January 2026.
  5. SPI calculation: in the 2026 cycle, notice ran from 29 days (Isle of Man) and 64 days (CAA Oregon) to 101 days (Verpact) and 129 days (CONAI plastic); for 2027, CAA published on 1 October 2026, 92 days ahead, and Recycle BC on 21 October, 72 days ahead.
  6. SPI calculation: under the UK’s cost-neutral modulation, the green discount needed to offset a red factor of 1.2 is 5.9% at a 21% red share of rated tonnage, rising to 29.6% at a factor of 2.0, against PackUK’s provisional figure of about 9% for year 2 (Exhibit 10).

Who sets and who approves the schedule in 14 markets

Exhibit 2 is the core of this piece: for each market, the body that sets the schedule, the body that approves or checks it, the costs the fee must cover and when the schedule is published. It is built from each market’s law or licence and the scheme’s own fee documents, read between 14 October and 3 November 2026.

Exhibit 2In 14 fee markets, who sets the fee, who approves it, what it covers and when it is published
MarketWho sets the scheduleWho approves or checks itCosts the fee must coverWhen it is published
Austria, ARAARA, one of several licensed systemsMinistry notified of planned changes in advance, with calculation basis and auditor's opinion (VerpackVO § 9(3), § 13(3))Collection from point of origin, sorting and recovery, net of secondary material revenue, per tariff categoryOne sheet a year; 2026 sheet dated 29 Sep 2025, 2027 sheet 28 Sep 2026
Belgium, Fost PlusFost Plus board, in JuneSent with method to the Interregional Packaging Commission; general meeting confirmsReal cost deficit per material: collection, sorting, recycling less bale revenueRates explained publicly in September; 2026 on 24 Sep 2025
British Columbia, Recycle BCRecycle BC, by its Four-Step Fee MethodologyMinistry approves the plan that sets allocation rules (17 Sep 2025); fees presented at the Annual Producers MeetingMaterial management net of commodity revenue, administration, resident awarenessFourth quarter; 2027 schedule on 21 Oct 2026
Colorado, CAACAA as the appointed PROCDPHE executive director approves the plan and amendments; advisory board reviews100% of net recycling services costs, administration capped at 5%, reserve2026 dues on 13 Oct 2025; 2027 on 1 Oct 2026
France, CiteoCiteo, under its cahier des chargesStakeholder committee opinion before decisions; state can fix modulations by arrêtéMainly support to local authorities for collection and sortingSeptember of the year before
Ireland, RepakRepak, with producers and the DepartmentFee structure shown to the Minister's satisfaction (approval, section 9)Net necessary costs of a cost-efficient serviceAnnual fee sheet; invoices January and July
Isle of Man, plastic packaging taxUK Parliament, Finance Act 2021 section 45Treasury aligns the Manx rate with the UK rateNot a cost-recovery feeTreasury notice; 3 Mar 2026 for 1 Apr 2026
Italy, CONAICONAI Board of DirectorsStatute approved by ministerial decree; no fee approval found in art. 224Separate collection, recycling and recovery, via seven material consortiaAnnounced months ahead; changes on 1 Jan, 1 Jul or 1 Oct
Luxembourg, ValorluxValorluxGeneral assembly approves; approval Art. 4 sets cost floor and seven modulation criteriaAt least the costs the law places on producers, plus set single-use plastic costsAutumn for the next year (GV October 2025)
Netherlands, VerpactVerpact, each year, on expected costsAgreement 2023 to 2027 declared generally binding; yearly ministerial sign-off not confirmedCosts of legal collection, recycling and reuse duties, with past surpluses or deficitsForecast in July, final table in autumn; 2026 on 22 Sep 2025
Oregon, CAACAA as the PRODEQ approves the plan; fees must follow it; alternative fee structures need DEQ approvalTotal system cost plus reserves, regulatory costs and PRO administration2026 on 29 Oct 2025; 2027 on 1 Oct 2026
Portugal, SPVSociedade Ponto Verde, under its licenceLicence by APA and DGAE (28 Jun 2024); approver of each table not confirmedSelective collection and sorting by municipal and concession systems2026 table in Dec 2025, reissued Jun 2026
Spain, EcoembesEcoembes, as a collective SCRAPRD 1055/2022 sets the cost limits; approver of the table not confirmedSeparate collection, transport, treatment, information, awareness and data, at a cost-efficient levelSummer of the year before; 2027 prices in Aug 2026
United Kingdom, PackUKPackUK, the scheme administrator (SI 2024/1332, reg. 60)Public body; modulation rules in a published statement, first review by 2028Net council cost for household packaging plus PackUK running, information and bad debt costsCalculation in November 2026, notice of liability by end of November

Source: SPI fee-market files (fee_setting and scheme_explainer sections), 14 Oct 2026; governing laws and scheme documents listed in Sources, consulted to 3 Nov 2026 (SPI summary), checked 13 Oct 2026.

SPI summary of published rules, not legal advice. 'Not confirmed' means SPI found no published rule on that point. Isle of Man is a tax, included because it sits in the SPI calculator.

Three things stand out. First, the word “approval” means different things. In Oregon, Colorado and British Columbia the regulator approves a plan, and the plan, not each schedule, carries the method. In Ireland the approval sets conditions on the fee structure itself. In Luxembourg the ministerial approval sets the floor and the criteria, while Valorlux’s general assembly approves the numbers.

Second, competition changes the picture. ARA in Austria held a 72.2% share of licensed volume in 2024 against other licensed systems (ARA general assembly, 18 June 2025). Where producers can switch, price discipline comes partly from the market and the regulator’s role is to police tariff principles, not to set rates.

Third, the gaps are real. SPI could not find a published rule naming who approves the yearly tables in Spain, Portugal or the Netherlands. SPI has not yet confirmed whether Spanish, Portuguese or Dutch authorities sign off each year’s numbers, and readers should ask their scheme directly.

What the law says EPR fees must cover

Fee methods differ, but the legal tests behind them are close. In the EU the anchor is Article 8a(4) of the Waste Framework Directive, which says producer contributions must cover separate collection, transport and treatment, information to waste holders and data reporting, net of revenue from reuse, material sales and unclaimed deposits; must be modulated where possible in collective schemes; and must not exceed the costs of a cost-efficient service (Directive 2008/98/EC, consolidated 5 July 2018). Regulation (EU) 2025/40 has applied since 12 August 2026, and the national rules below still carry these tests.

Exhibit 3The legal cost tests behind EPR fees are close across markets, but only Colorado caps administration in law
InstrumentFloor: what fees must coverCeiling or limitModulation rule
EU, Waste Framework Directive Art. 8a(4)Collection, transport, treatment, information, data, net of revenuesNot above cost of a cost-efficient serviceModulate where possible, life-cycle approach
Spain, RD 1055/2022Total cost of managing the packaging waste generatedNot above necessary costs; excess income returned annuallyCriteria listed; effects reviewed within four years
Ireland, Repak approvalPolluter pays, by quantity placed on marketNet necessary costs; cost-efficient serviceModulated under the Directive, adapted to Regulation (EU) 2025/40
Colorado, C.R.S. 25-17-705100% of net recycling services costs of providersAdministration no more than 5% of duesBonus and malus factors in the plan; state bonus schedule
Oregon, ORS 459A.884Enough to meet the organisation's financial obligationsProportional to the cost of each product typeHigher base fees for items not accepted in collection
Luxembourg, Valorlux approval Art. 4At least the costs the law places on producersNot stated in Art. 4Seven criteria, from quantity to hazardous substances
Italy, D.Lgs. 152/2006 art. 224Fee in proportion to quantity, weight and type of materialNot stated in art. 224Set by CONAI under its statute
United Kingdom, SI 2024/1332Net council disposal cost for household packaging, plus scheme costsModulation does not raise total feesRed, amber, green by recyclability rating
Austria, VerpackVO § 9Collection, sorting and recovery per tariff categoryNo cross-subsidy between categories; auditor checksNot by recyclability grade

Source: Directive 2008/98/EC Art. 8a(4); RD 1055/2022 preamble; Repak approval 2026 to 2035, sections 9 and 10; C.R.S. 25-17-705; ORS 459A.884; Valorlux approval Art. 4; D.Lgs. 152/2006 art. 224; SI 2024/1332 reg. 60 and PackUK base fee notes; VerpackVO § 9, checked 13 Oct 2026.

SPI summary. Italian and Austrian texts read in unofficial consolidations (Brocardi.it, gesetzefinden.at). Oregon statute read on Oregon.public.law.

The words “net necessary cost” do a great deal of work. In Ireland, the approval’s success factors list “Net Necessary Cost %” as a measured indicator, and Repak is working with the Department on a consultant’s review of the net necessary cost system (Repak approval; Repak annual report 2025). In Spain, the decree’s preamble says contributions must be set transparently between the actors concerned, taking into account costs incurred by public and private waste managers, and that collective systems must return excess income each year (RD 1055/2022, preamble IV).

SPI analysis

The cost floor is set by law almost everywhere, but the ceiling is usually a principle rather than a number. Colorado’s 5% administration cap is the only hard numeric ceiling SPI found in the 14 markets. Elsewhere, the ceiling depends on who audits “cost-efficient”, which is a governance question, not a formula.

How are EPR fees calculated? From net cost to a rate per kilogram

Every EPR scheme whose method SPI could read in full follows four moves: build a cost budget, assign it to materials, net off material revenue, and divide by reported tonnage. The order and the extras differ (Exhibit 4).

Exhibit 4How EPR fees are calculated: six schemes run the same four steps with different extras
Scheme1. Cost budget2. Assign to materials3. Net off revenue4. Divide byCarry-over
Fost PlusCollection, sorting, recycling, operating costsPer material categoryBale salesMembers' tonnage per materialInto next year's rates
PackUKNet council disposal cost plus PackUK overheadsPer materialCouncil material incomeHousehold tonnage placed on marketYear 1 fees stood despite resubmitted data
CAA OregonCollection, transport, processing, capital access, expansion, reserves, PRO administrationPer material categoryCommodity revenue credited to earnersReported supply tonnageRates reset each year on new supply data
Recycle BCMaterial management, administration, awarenessFair share to every material, extra to underperformersCommodity revenue to earners; beverage revenue firstSupplied weightAnnual review at producers meeting
VerpactExpected costs of legal duties for the coming yearPer materialNot stated on the tariff pageExpected tonnagePast surpluses or deficits included
ARA (VerpackVO)Collection from point of origin, sorting, recoveryPer tariff categorySecondary material and reuse revenueMass placed per categoryAnnual post-calculation checked by auditor

Source: Fost Plus, Packaging EPR rates: what, why and how; GOV.UK PackUK base fees (27 Jun 2025) and modulation statement; CAA-401 (29 May 2025); Recycle BC plan (19 Aug 2025); Verpact Tarieven page; VerpackVO § 9(2), checked 13 Oct 2026.

SPI summary of each scheme's published method. 'Carry-over' is how a past surplus or shortfall is treated.

The shared logic has a consequence producers often miss: rates move when tonnage moves, even if costs do not. Oregon DEQ stresses that because rates follow reported supply, they change every year and late or missing data distorts them (Oregon DEQ, producers of covered products). PackUK’s year 2 calculation left the costs of littered and on-the-go packaging out of the numerator while keeping their tonnage in the denominator (GOV.UK, updated 19 December 2025), which lowers the rate per tonne for everyone.

In practice: Fost Plus.

Fost Plus publishes its method in plain terms. Rates are calculated on the real cost deficit for each recycled material; the board approves budget and rates in June; they go to the Interregional Packaging Commission with the calculation method; and the general meeting confirms them (Fost Plus, what, why and how). Non-recyclable packaging is priced at least double the highest recyclable rate, and the extra money is shared across recyclable materials by recycling percentage. Surpluses and shortfalls for a material flow into its rate the following year, so a member’s bill in year two partly settles year one.

In practice: CAA in Oregon.

CAA’s first-year explainer of 29 May 2025 starts from total system cost and adds reserves, regulatory costs and PRO administration, then credits commodity revenue to the categories that earned it and divides by reported supply to reach a base rate per pound (CAA-401). The 2026 schedule prints a base fee, a system investment portion and a final rate for every line; the investment portion was zero on every row, so the final rate equalled the base (CAA 2026 Oregon schedule). Oregon’s statute requires fees for each product type to be proportional to the costs they cause the PRO and lets CAA propose an alternative structure only with DEQ approval (ORS 459A.884(1) and (5)). For the line-by-line rates, see SPI’s Oregon and Colorado schedule piece.

Extended producer responsibility fees, market by market: the yearly cycle in eight markets

Exhibit 4 shows the method where schemes publish it in full. The yearly cycle matters as much, because it is what a producer has to plan around. Here it is for eight markets, including two from Exhibit 4 where the cycle adds something.

Spain. Ecoembes publishes one price per kilogram for each material and format, with separate lines for packaging inside the Single-Use Plastics Directive scope, and then moves the base price up or down per packaging element through its eco-modulation guide (Ecoembes Precios 2026; Guía de ecomodulación 2026). The guide is calibrated on final annual declaration data for year n-2, and the euros raised by penalised tonnes are the ceiling for bonuses in the same fraction, so the modulation is self-funding by design. The legal frame is RD 1055/2022, whose preamble lists the modulation criteria and provides for an analysis of their effects within four years.

Portugal. Sociedade Ponto Verde (SPV) sets a value per kilogram by material, by urban or non-urban flow and, for single-use plastic cups, by unit, with a reduced value 10% below the base for packaging that meets every eco-modulation criterion for its material (SPV Tabela VPV 2026). The UNILEX law requires each producer’s contract with the managing entity to state the financial contributions owed and how they are updated (UNILEX, article 10(3), per the APA manual). SPV’s 2026 table first appeared in December 2025 and was reissued in June 2026 with the same values. SPV also reports a fall of about 26% in the resale prices of recovered materials in 2025, which raises the net cost the fees must cover (SPV activity report 2025).

Luxembourg. Valorlux publishes its tariff each autumn for the following year after its general assembly; the 2026 detailed table is marked GV October 2025 (Valorlux 2026 table). Its board also sets a minimum contribution, which the general conditions cap at EUR 125, and members pay quarterly advances adjusted later by a complementary invoice or credit note (Valorlux general conditions, articles 5.3 and 5.4).

Netherlands. Verpact sets one tariff per material each year from the expected costs of meeting its legal duties, and folds in surpluses or deficits from earlier years (Verpact Tarieven). The fee is owed by every obliged firm, signatory or not, because the state has declared the 2023 to 2027 waste management contribution agreement generally binding (Ondernemersplein). Modulation is a discount on the plastic tariff adopted under the agreement’s annex, not a set of bands, and it is redesigned for 2027 (Verpact Tariefdifferentiatie 2027).

Italy. CONAI’s Board of Directors sets each value after monitoring the finances of the material consortia and announces changes months ahead with a stated effective date (CONAI, 25 May 2026). The fee is charged at the first transfer of finished packaging inside Italy, on the seller’s invoice, rather than when goods reach the shelf, so the fee cycle runs through the supply chain’s own invoicing (CONAI 2026 value table).

Colorado. CAA’s 2026 dues schedule, published on 13 October 2025, lists base dues per material and then applies eco-modulation automatically, as the Act requires (CAA 2026 Colorado schedule). The Act also requires an annual report with the schedule of dues by weight for each material, the total collected and the reasons for changes, which the advisory board reviews and the department posts (C.R.S. 25-17-709(2)(a)). The executive director had to produce a bonus schedule by 1 January 2026 and must revisit it each year.

British Columbia. Recycle BC’s plan, approved on 17 September 2025, sets the allocation rules: every obligated material bears a fair share of cost even when it is not collected, commodity revenue goes only to the materials that earn it, and extra cost is loaded onto uncollectable or underperforming categories to fund improvement (Recycle BC plan). Beverage container revenue is netted off gross programme cost before material fees are worked out. Recycle BC’s 2027 schedule came with cause-of-change graphs that split each line’s movement into the factors in its model, as SPI’s report on the 2027 schedule and Canada EPR overview set out.

Isle of Man. The Island runs no calculation. Its Treasury notice of 3 March 2026 says the rate must stay aligned with the UK figure, which Westminster sets in section 45 of the Finance Act 2021, and the Manx change took effect on 1 April 2026, the same day as the UK one (Isle of Man Government, 3 March 2026). Recycled content decides the bill: components below 30% recycled plastic pay, those at or above it do not.

SPI analysis

The eight markets fall into three groups. Spain, Portugal and Colorado publish modulation rules in detail, while their base-rate arithmetic sits in legal tests or plans rather than a worked public method. Italy and Luxembourg publish least and rely on board or assembly decisions inside the licence. British Columbia and the Netherlands publish both the method and the cause of each change. For a buyer, both groups make the scheme’s annual report and assembly papers the best public source of the cost budget behind the rate.

A framework: four ways to govern a fee schedule

Exhibit 5 sets out SPI’s framework. It sorts markets by one question: who has the last word on the yearly number, and what check, if any, sits before it.

Exhibit 5Four governance models: the further down, the more the scheme's own bodies decide and the more producer influence runs through membership
ModelMarketsWho has the last wordCheck before it appliesWhere a producer can push
A. State sets the chargeUK, Isle of ManPublic body or statutePublished statement or Finance ActConsultations, RAM change requests
B. Regulator approves the planOregon, Colorado, British ColumbiaScheme, inside an approved planPlan approval and amendmentsPlan consultations, advisory board, producers meeting
C. Scheme sets, public body checksBelgium, Austria, France, IrelandScheme board or assemblyCommission, ministry, stakeholder committee or MinisterStakeholder committee, general meeting, Department process
D. Scheme sets inside licenceItaly, Netherlands, Spain, Portugal, LuxembourgScheme board or general assemblyLicence conditions, statute approval, auditsMembership and trade association seats

Source: SPI framework built from Exhibit 2, checked 5 Nov 2026.

SPI classification. Markets can sit between models; each is placed where the yearly decision sits.

Model A gives the most predictable method and the least room to bargain. PackUK publishes its modulation rules in a statement, and the red factor rises on a set path: 1.2 in year 2, 1.6 in year 3 and 2.0 in year 4 (PackUK modulation statement). The Isle of Man has no method of its own at all; its Treasury says the rate must stay aligned with the UK rate under the 1979 Customs and Excise Agreement (Isle of Man Government, 3 March 2026).

Model B front-loads the argument. In Colorado, the PRO must seek and consider advisory board input when it drafts the plan; the board reviews the plan and any proposed amendment and forwards a recommendation; and the executive director approves or rejects within 120 days, on the plan requirements alone (C.R.S. 25-17-705(4), (5) and (6)). The plan must provide for annual updates to the dues schedule. The statute does not say whether each annual update counts as an amendment needing approval, and SPI has not yet confirmed CDPHE’s reading. British Columbia’s ministry approved Recycle BC’s plan on 17 September 2025 and will next review it by 15 April 2028 (Recycle BC plan and approval).

Model C adds a checkpoint without handing the pen to the state. Austria’s ordinance requires each system to publish general tariffs per category, treat partners equally, allow no rebates and notify planned tariff changes to the minister in good time, attaching the calculation basis and an auditor’s opinion on the tariff principles (VerpackVO § 9(2) and (3), unofficial consolidation). France goes furthest: a stakeholder committee of producers, waste operators, local authorities and associations must publish an opinion before Citeo decides on the contribution amount, support scales and eco-modulation proposals, and Citeo may not act before the opinion is out unless it shows urgency (Citeo, governance fact sheet, 18 February 2025).

Model D relies on the licence and on membership. Italian law has CONAI determine the fee in proportion to the quantity, weight and type of packaging, under a statute the environment minister approves by decree (D.Lgs. 152/2006, art. 224(1) and (3)(h), unofficial text). Valorlux’s ministerial approval requires contributions to cover at least the costs the law places on producers and to be modulated by seven criteria, but Article 4 contains no step for ministerial approval of the rates (Valorlux approval, Art. 4).

SPI analysis

The model predicts the type of surprise. Model A surprises on timing, because the bill arrives late. Model B surprises on data, because rates move with reported supply. Model C surprises least, because a third party sees the numbers first. Model D can surprise on mid-year changes, because the decision sits inside the scheme.

Where producers get a say before fees are final

The governance model decides where influence works. Exhibit 6 lists the formal routes SPI found in published documents.

Exhibit 6Eight formal routes for producers to be heard on fees, from France's stakeholder vote to the UK's RAM change requests
MarketRouteWhat it coversLatest dated example
FranceComité des parties prenantes opinionContribution amount, support scale, eco-modulation8 Jun 2026: 2027 eco-modulation approved, 6 for, 0 against, 5 abstentions
British ColumbiaAnnual Producers MeetingFee rates for the coming year and method changes2026 meeting materials linked from the fee schedule page
ColoradoAdvisory board reviewPlan and plan amendments, annual reportBoard meeting of 28 Oct 2026
IrelandFee-setting process with producers and the DepartmentFee structureApproval in force from 1 Jan 2026
BelgiumFost Plus general meetingConfirms budget and ratesEach year after the June board
LuxembourgValorlux general assemblyApproves next year's tariffOctober 2025 for 2026
ItalyCONAI membership through consortiaBoard decisions on the fee25 May 2026 plastic decision after talks with the supply chain
United KingdomRAM change requests through UK Packaging PRORecyclability rules that drive modulationEvidence due 31 Dec 2026 for RAM 2028

Source: Citeo CPP opinion (8 Jun 2026) and governance fact sheet; Recycle BC fee schedule page and plan; C.R.S. 25-17-705; Repak approval s. 9; Fost Plus, what, why and how; Valorlux 2026 table; GOV.UK news (22 Oct 2026) as reported by SPI; CONAI guide 2026 (SPI summary), checked 13 Oct 2026.

Formal routes only. Trade association lobbying is not listed.

The French vote shows how the route works in practice. On 8 June 2026, Citeo’s stakeholder committee approved the eco-modulation proposals for 2027 with 6 votes in favour, none against and 5 abstentions (Citeo CPP opinion, 8 June 2026). SPI has not yet confirmed Citeo’s 2027 tariff against Citeo’s own guide.

France also shows the state stepping into modulation directly. The arrêté of 5 September 2025 sets primes for recycled plastic across several EPR streams, including household packaging. Its recitals cite the opinion of the inter-sector EPR commission of 13 March 2025, a public consultation from 11 March to 1 April 2025 and notification to the European Commission on 4 September 2025, and it applies from 1 January 2026 (arrêté of 5 September 2025, via AIDA). Citeo’s 2026 guide says that prime can be combined only with the reduction, grouping and small-format maluses (Citeo guide 2026).

Ontario, outside the 14 markets, is moving the other way, from scheme discretion toward rules. ERO notice 026-1058, posted on 27 October 2026 with comments to 26 November, would require PROs to publish proposed and final fee schedules and itemise system costs on invoices (ERO 026-1058). SPI’s report on the notice covers the detail.

Which data the fee rests on, and how it is trued up

A fee is a rate times a tonnage, and the tonnage period is a governance choice too. Exhibit 7 shows which data each scheme bills on and how errors are corrected.

Exhibit 7Most schemes bill on last year's tonnage and settle the gap later; PackUK froze its year 2 data on 1 September 2026
SchemeTonnage the fee is billed onHow it is corrected
RepakSame half of the previous year (H1 2026 invoice on H1 2025 tonnage)Next half-year return
SPVPrior year's declared weightsAdjusted for prior invoicing and current values
EcoembesEco-modulation calibrated on year n-2 final dataBonus pool capped by malus revenue
VerpactCurrent-year estimate (Opgaaf)Annual declaration (Aangifte) before 1 April; checks up to five years
Fost PlusAdvance invoices on last declarationAnnual declaration by 28 February; surpluses into later rates
PackUK2025 data, resubmissions to 1 Sep 2026No producer-wide recalculation planned
CAA OregonSupply reported for the prior yearRates reset each year
ARAPeriodic volume reportsAnnual post-calculation with auditor confirmation

Source: Repak QF 509; SPV Adira ao Sistema Ponto Verde; Ecoembes Guía de ecomodulación 2026; Verpact Beleid 2026; Fost Plus declaration page; PackUK operational plan (10 Aug 2026); CAA-401; VerpackVO § 9, checked 5 Nov 2026.

SPI summary of published billing rules.

In practice: Repak.

Repak’s approval for 1 January 2026 to 30 September 2035, with reviews planned in the first halves of 2029 and 2032, makes the fee-setting process a regulated one: fees follow the polluter-pays principle, must not exceed the cost of a cost-efficient service, and the structure must be shown to the Minister’s satisfaction to meet the Waste Framework Directive (Repak approval, sections 9 and 22). Repak also spreads the fee along the chain: the material maker, converter and retailer pay fixed shares and the brand holder carries the variable share. Invoices go out in January and July on the same half of the previous year, so a tonnage cut in 2026 shows in 2027 invoices (Repak QF 509).

The PackUK case is the opposite. Its operational plan says the year 2 notice of liability will be issued by the end of November 2026, after the fees are calculated that month, on data frozen on 1 September 2026, with no plan for a producer-wide recalculation (PackUK operational plan, updated 10 August 2026). SPI’s report on the November notices sets out the payment terms.

When EPR fees are published: lead times from 29 to 129 days

The date a schedule appears is the producer’s real budget deadline. Exhibit 8 counts the days from the public release SPI could date to the day the fee first applied.

Exhibit 8Producers got 29 to 129 days' notice of new fees in the 2026 cycle; CAA moved its 2027 release earlier, to 92 days Unit: days from publication to first application
Exhibit 8. Producers got 29 to 129 days' notice of new fees in the 2026 cycle; CAA moved its 2027 release earlier, to 92 days11 bars. Largest: CONAI plastic change, 25 May to 1 Oct 2026, 129.CONAI plastic change, 25 May to 1 Oct2026CONAI plastic change, 25 May to 1 Oct 2026: 129 days from publication to first application129PackUK year 2 illustrative, 16 Dec2025 to 1 Apr 2026PackUK year 2 illustrative, 16 Dec 2025 to 1 Apr 2026: 106 days from publication to first application106Verpact 2026, 22 Sep 2025 to 1 Jan2026Verpact 2026, 22 Sep 2025 to 1 Jan 2026: 101 days from publication to first application101Fost Plus 2026 explainer, 24 Sep 2025to 1 Jan 2026Fost Plus 2026 explainer, 24 Sep 2025 to 1 Jan 2026: 99 days from publication to first application99ARA 2027, 28 Sep 2026 to 1 Jan 2027ARA 2027, 28 Sep 2026 to 1 Jan 2027: 95 days from publication to first application95ARA 2026, 29 Sep 2025 to 1 Jan 2026ARA 2026, 29 Sep 2025 to 1 Jan 2026: 94 days from publication to first application94CAA Oregon and Colorado 2027, 1 Oct2026 to 1 Jan 2027CAA Oregon and Colorado 2027, 1 Oct 2026 to 1 Jan 2027: 92 days from publication to first application92CAA Colorado 2026, 13 Oct 2025 to 1Jan 2026CAA Colorado 2026, 13 Oct 2025 to 1 Jan 2026: 80 days from publication to first application80Recycle BC 2027, 21 Oct 2026 to 1 Jan2027Recycle BC 2027, 21 Oct 2026 to 1 Jan 2027: 72 days from publication to first application72CAA Oregon 2026, 29 Oct 2025 to 1 Jan2026CAA Oregon 2026, 29 Oct 2025 to 1 Jan 2026: 64 days from publication to first application64Isle of Man tax rate, 3 Mar to 1 Apr2026Isle of Man tax rate, 3 Mar to 1 Apr 2026: 29 days from publication to first application29Exhibit 8. Producers got 29 to 129 days' notice of new fees in the 2026 cycle; CAA moved its 2027 release earlier, to 92 days11 bars. Largest: CONAI plastic change, 25 May to 1 Oct 2026, 129.CONAI plastic change, 25 May to 1 Oct 2026CONAI plastic change, 25 May to 1 Oct 2026: 129 days from publication to first application129PackUK year 2 illustrative, 16 Dec 2025 to 1 Apr2026PackUK year 2 illustrative, 16 Dec 2025 to 1 Apr 2026: 106 days from publication to first application106Verpact 2026, 22 Sep 2025 to 1 Jan 2026Verpact 2026, 22 Sep 2025 to 1 Jan 2026: 101 days from publication to first application101Fost Plus 2026 explainer, 24 Sep 2025 to 1 Jan 2026Fost Plus 2026 explainer, 24 Sep 2025 to 1 Jan 2026: 99 days from publication to first application99ARA 2027, 28 Sep 2026 to 1 Jan 2027ARA 2027, 28 Sep 2026 to 1 Jan 2027: 95 days from publication to first application95ARA 2026, 29 Sep 2025 to 1 Jan 2026ARA 2026, 29 Sep 2025 to 1 Jan 2026: 94 days from publication to first application94CAA Oregon and Colorado 2027, 1 Oct 2026 to 1 Jan2027CAA Oregon and Colorado 2027, 1 Oct 2026 to 1 Jan 2027: 92 days from publication to first application92CAA Colorado 2026, 13 Oct 2025 to 1 Jan 2026CAA Colorado 2026, 13 Oct 2025 to 1 Jan 2026: 80 days from publication to first application80Recycle BC 2027, 21 Oct 2026 to 1 Jan 2027Recycle BC 2027, 21 Oct 2026 to 1 Jan 2027: 72 days from publication to first application72CAA Oregon 2026, 29 Oct 2025 to 1 Jan 2026CAA Oregon 2026, 29 Oct 2025 to 1 Jan 2026: 64 days from publication to first application64Isle of Man tax rate, 3 Mar to 1 Apr 2026Isle of Man tax rate, 3 Mar to 1 Apr 2026: 29 days from publication to first application29

Source: SPI calculation from publication dates in CONAI (25 May 2026), Verpact (22 Sep 2025), Fost Plus (24 Sep 2025), ARA 2026 and 2027 sheets, CAA Colorado and Oregon 2026 schedules, CAA 2027 schedules (1 Oct 2026), Recycle BC 2027 schedule (21 Oct 2026), Isle of Man Treasury (3 Mar 2026) and PackUK illustrative fees (16 Dec 2025) (SPI summary), checked 13 Oct 2026.

Only schemes with an exact public date are shown. Fost Plus rates are set by its board in June; the bar uses the public explainer date. PackUK year 2 is illustrative only: the confirmed fee comes in the November 2026 notice, 243 days after the year began on 1 April 2026.

Show the data
Exhibit 8. Producers got 29 to 129 days' notice of new fees in the 2026 cycle; CAA moved its 2027 release earlier, to 92 days (days from publication to first application)
ReleaseDays (days from publication to first application)
CONAI plastic change, 25 May to 1 Oct 2026129
PackUK year 2 illustrative, 16 Dec 2025 to 1 Apr 2026106
Verpact 2026, 22 Sep 2025 to 1 Jan 2026101
Fost Plus 2026 explainer, 24 Sep 2025 to 1 Jan 202699
ARA 2027, 28 Sep 2026 to 1 Jan 202795
ARA 2026, 29 Sep 2025 to 1 Jan 202694
CAA Oregon and Colorado 2027, 1 Oct 2026 to 1 Jan 202792
CAA Colorado 2026, 13 Oct 2025 to 1 Jan 202680
Recycle BC 2027, 21 Oct 2026 to 1 Jan 202772
CAA Oregon 2026, 29 Oct 2025 to 1 Jan 202664
Isle of Man tax rate, 3 Mar to 1 Apr 202629

Two schemes publish much earlier than the rest. Ecoembes put its 2027 prices online in August 2026, and Verpact published a 2027 forecast in July 2026, presented at a webinar on 7 July, before setting final tariffs that it says largely match it (Verpact Tarieven page). Citeo’s calendar is fixed: tariff and eco-modulation are announced in September of the year before the packaging is placed on the market (Citeo guide 2026). For the euro schemes’ 2025 to 2026 moves, see SPI’s Benelux fees piece.

SPI analysis

The North American schemes publish latest, because their rates depend on supply data reported in the same year: CAA’s 2027 Oregon fees rest on 2025 supply data due by 31 May 2026. The UK publishes last of all, after the year has started. A producer that budgets in September for the following calendar year will have final numbers for ARA, Verpact, Fost Plus, Ecoembes and Citeo, but not for CAA in a year when it publishes in late October, and not for PackUK.

Mid-year changes and exit rights

An annual schedule is not always annual. Exhibit 9 lists the published rules on changing fees inside a year.

Exhibit 9Four schemes publish rules that allow fee changes inside a year; Ontario proposes 90 days' notice
SchemeMid-year ruleProducer protection
ARATariffs can change at the start of any month, ideally with one month's noticeRight to terminate if notice reaches ARA within three weeks of a published increase
CONAIValues can change on 1 January, 1 July or 1 OctoberChanges announced months ahead with a stated date
SPV2025 glass and aluminium values revised, approved on 1 August 2025Not stated in the table
CiteoRates can be revised if regulation changes or public authorities askNot stated in the guide
Ontario (proposal)Mid-year increases limited to once a year90 days' notice before a mid-year rise

Source: ARA general terms (29 Nov 2024), VII.3 and XXIII.6.b; CONAI 2026 value table; SPV Tabela VPV 2025 atualizada; Citeo guide 2026; SPI report on Ontario ERO 026-1058, checked 5 Nov 2026.

SPI summary. Ontario is outside the 14 markets and its rule is a proposal.

CONAI’s October 2026 change is the clearest recent case. Its Board of Directors set new plastic values after talks with the supply chain and the plastics consortium COREPLA, effective 1 October 2026, citing volatile markets, rising management costs, weak demand for some recycled fractions, mainly in bands B2 and C, and the aim of keeping recycling at 50% or more (CONAI, 25 May 2026). The start date, CONAI said, balanced the system’s finances against giving companies enough notice.

Scenarios: how modulation shares out a fixed UK bill

Modulation changes who pays, not how much the system costs, in schemes that are cost-neutral by design. PackUK’s statement says modulation will affect how costs are allocated by material and will not raise total disposal fees (PackUK modulation statement). Fost Plus shares non-recyclable revenue across recyclable materials, and Ecoembes caps bonuses at the money raised by maluses in the same fraction (Ecoembes guide 2026). Exhibit 10 shows what that means for the UK green discount.

Exhibit 10SPI calculation: at a 21% red share, a cost-neutral UK scheme needs a 5.9% green discount at factor 1.2 and 29.6% at factor 2.0
ScenarioRed shareGreen shareFactor 1.2 (year 2)Factor 1.6 (year 3)Factor 2.0 (year 4)
Low: red falls to 10%10%82%2.4%7.3%12.2%
Base: H1 2025 RAM data21%71%5.9%17.7%29.6%
High: red rises to 30%30%62%9.7%29.0%48.4%

Source: SPI calculation from PackUK modulation statement (factors 1.2, 1.6, 2.0) and PackUK year 2 illustrative fees (71% green, 8% amber, 21% red of RAM-rated tonnage, H1 2025) (SPI summary), checked 13 Oct 2026.

Formula: discount = (factor minus 1) x red share / green share, assuming amber pays the base fee and the base equals total cost over rated tonnage. Low and high red shares are SPI assumptions with amber held at 8%. PackUK's provisional year 2 discount is about 9%; SPI has not yet confirmed how PackUK treats tonnage without a RAM rating, which may explain the gap. Percentages only; no currency.

The table carries a governance point. In a cost-neutral design, a green-rated producer’s bill depends on how much red packaging other producers report, which no single firm controls. The rising factor raises the stakes: at the base case, the discount needed triples from year 2 to year 3. PackUK says the factors will be reviewed no later than 2028, and its RAM change process runs to 31 December 2026 (PackUK modulation statement; GOV.UK, 22 October 2026). The tracker record PR-GB-002 holds the regulation.

Industry reaction

“Such costs shall be established in a transparent way between the actors concerned.”

European Union, Waste Framework Directive, Article 8a(4)(c), consolidated text of 5 July 2018

The sentence sets a process test, not a number. Ireland’s approval turns it into a named process with producers and the Department; most other markets leave it to the scheme’s own bodies.

“Any surpluses and shortfalls are incorporated into the rates for the following year.”

Fost Plus, Belgian household packaging scheme, Packaging EPR rates: what, why and how, consulted 3 November 2026

“We stellen de tarieven jaarlijks vast op basis van de verwachte kosten voor het komende kalenderjaar.”

Verpact, Dutch packaging producer organisation, Tarieven, consulted 3 November 2026

“Only once the household packaging waste disposal fee has been calculated can the modulated fees be calculated.”

In English: “We set the tariffs each year on the basis of the expected costs for the coming calendar year.”

PackUK, UK scheme administrator, Producer disposal fees modulation statement, GOV.UK, updated 17 February 2026

Read together, the scheme statements describe the same cycle: budget forward, settle backward, then modulate. The difference lies in who checks each step.

What leaders should do now

  1. Head of EPR compliance, by 31 December 2026: map each market you sell into against Exhibit 2, record who sets and who approves the schedule, and name the date the next one is published.
  2. Finance director, in the 2027 budget round: set budget deadlines by market, using the publication dates in Exhibit 8, and hold a contingency for PackUK and for any CAA schedule that arrives after your budget closes.
  3. Data owner, before each tonnage deadline (31 May for Recycle BC, 28 February for Fost Plus, 21 February and 21 August for Repak): check reported tonnage against sales, because rates in most schemes divide cost by the same tonnage.
  4. Government affairs, by 26 November 2026 for Ontario and 31 December 2026 for UK RAM 2028: use the formal routes in Exhibit 6, through your trade association where seats are held there.
  5. Procurement and legal, in the next contract review: read your scheme’s terms for mid-year change and exit rights, such as ARA’s three-week termination window, and check with counsel what notice your own contracts need.
  6. Packaging design leads, from January 2027: in cost-neutral schemes, treat a green rating as a discount that depends on other producers’ red tonnage, and model it as a range (Exhibit 10).

Questions for your board

  • In which of our markets does a public body see the fee schedule before it applies, and in which does the scheme decide alone?
  • How much of our EPR spend is set on tonnage we report, and who signs that data off?
  • Which of our schemes can change fees inside a year, and what notice would we get?
  • Are we represented, directly or through a trade body, on the committees and assemblies that approve fees?
  • What would a late UK notice of liability or CAA schedule do to our quarterly cash forecast?
  • If red packaging falls across the market, how much of our green discount would disappear?

What to watch

  • 26 November 2026: comments close on Ontario ERO notice 026-1058 on PRO fee publication and itemised invoices.
  • By 30 November 2026: PackUK issues year 2 notices of liability after calculating fees in November.
  • 11 December 2026: comments close on ARMA’s draft 2027 oversight fee in Alberta, outside the 14 markets.
  • 31 December 2026: evidence deadline for producer change requests to the UK RAM for 2028.
  • 1 January 2027: 2027 tables apply at ARA, Fost Plus, Verpact, Valorlux, Ecoembes, CAA Oregon and Colorado, and Recycle BC.
  • First half of 2029: first planned review of Repak’s approval.
Exhibit 11The fee-setting calendar: from Repak's new approval in January 2026 to its first review in 2029
  • past
  • next
Exhibit 11. The fee-setting calendar: from Repak's new approval in January 2026 to its first review in 202911 dated items from 1 Jan 2026 to 1 Jan 2027.202620272028Today1 Jan 2026: Repak approval 2026 to 2035 takes effect3 Mar 2026: Isle of Man Treasury announces the April rate25 May 2026: CONAI board sets new plastic values from 1 October8 Jun 2026: Citeo stakeholder committee approves 2027 eco-modulation proposals1 Sep 2026: PackUK year 2 data cut-off1 Oct 2026: CAA publishes 2027 Oregon and Colorado schedules21 Oct 2026: Recycle BC posts its 2027 schedule26 Nov 2026: Ontario ERO 026-1058 comments close30 Nov 2026: PackUK year 2 notices of liability due31 Dec 2026: UK RAM 2028 change requests due1 Jan 2027: 2027 schedules apply in most calendar-year schemesExhibit 11. The fee-setting calendar: from Repak's new approval in January 2026 to its first review in 202911 dated items from 1 Jan 2026 to 1 Jan 2027.202620272028Today1 Jan 2026: Repak approval 2026 to 2035 takes effect3 Mar 2026: Isle of Man Treasury announces the April rate25 May 2026: CONAI board sets new plastic values from 1 October8 Jun 2026: Citeo stakeholder committee approves 2027 eco-modulation proposals1 Sep 2026: PackUK year 2 data cut-off1 Oct 2026: CAA publishes 2027 Oregon and Colorado schedules21 Oct 2026: Recycle BC posts its 2027 schedule26 Nov 2026: Ontario ERO 026-1058 comments close30 Nov 2026: PackUK year 2 notices of liability due31 Dec 2026: UK RAM 2028 change requests due1 Jan 2027: 2027 schedules apply in most calendar-year schemes
  1. Repak approval 2026 to 2035 takes effectpast
  2. Isle of Man Treasury announces the April ratepast
  3. CONAI board sets new plastic values from 1 Octoberpast
  4. Citeo stakeholder committee approves 2027 eco-modulation proposalspast
  5. PackUK year 2 data cut-offpast
  6. CAA publishes 2027 Oregon and Colorado schedulespast
  7. Recycle BC posts its 2027 schedulepast
  8. Ontario ERO 026-1058 comments closenext
  9. PackUK year 2 notices of liability duenext
  10. UK RAM 2028 change requests duenext
  11. 2027 schedules apply in most calendar-year schemesnext

Source: Repak approval 2026 to 2035; Isle of Man Treasury (3 Mar 2026); CONAI (25 May 2026); Citeo CPP (8 Jun 2026); CAA 2027 schedules; Recycle BC 2027 schedule; PackUK operational plan; ERO 026-1058; GOV.UK (22 Oct 2026) (SPI summary), checked 5 Nov 2026.

Dates as given in each source, consulted to 3 November 2026.

Show the data
Exhibit 11. The fee-setting calendar: from Repak's new approval in January 2026 to its first review in 2029
DateLabelCategoryLink
2026-01-01Repak approval 2026 to 2035 takes effectpasthttps://repak.ie/images/uploads/downloads/Repak_Approval_2026_to_2035.pdf
2026-03-03Isle of Man Treasury announces the April ratepasthttps://www.gov.im/news/2026/mar/03/plastic-packaging-tax-rate-to-increase-from-1-april-2026/
2026-05-25CONAI board sets new plastic values from 1 Octoberpasthttps://www.conai.org/news-e-press/imballaggi-in-plastica-definiti-i-nuovi-valori-del-contributo-ambientale-conai/
2026-06-08Citeo stakeholder committee approves 2027 eco-modulation proposalspasthttps://www.citeo.com/wp-content/uploads/2026/06/8-juin-2026-Avis-du-Comite-des-Parties-Prenantes-de-la-filiere-des-emballages-menagers-et-papiers-graphiques-de-Citeo.pdf
2026-09-01PackUK year 2 data cut-offpasthttps://www.gov.uk/government/publications/packuk-operational-plan/packuk-operational-plan-2026-to-2027
2026-10-01CAA publishes 2027 Oregon and Colorado schedulespasthttps://circularactionalliance.org/circular-action-alliance-colorado
2026-10-21Recycle BC posts its 2027 schedulepasthttps://recyclebc.ca/producers/reporting-fees/fee-schedule/
2026-11-26Ontario ERO 026-1058 comments closenexthttps://ero.ontario.ca/notice/026-1058
2026-11-30PackUK year 2 notices of liability duenexthttps://www.gov.uk/government/publications/packuk-operational-plan/packuk-operational-plan-2026-to-2027
2026-12-31UK RAM 2028 change requests duenexthttps://www.gov.uk/government/news/a-new-approach-to-ram-updates
2027-01-012027 schedules apply in most calendar-year schemesnexthttps://www.fostplus.be/en/members/green-dot-rates

Methodology

  • Data used: the fee_setting and scheme_explainer sections of SPI’s 14 fee-market files (Austria, Belgium, British Columbia, Colorado, France, Ireland, Isle of Man, Italy, Luxembourg, Netherlands, Oregon, Portugal, Spain, United Kingdom), as of 14 October 2026, brought up to date from the primary sources listed below between 14 October and 3 November 2026.
  • Classification: each market is placed in one governance model (Exhibits 1 and 5) by where the yearly decision sits and what check, if any, comes before it. This is SPI’s reading, not a legal classification. A plan approval counts as a check on the method, not on the yearly number.
  • Legal texts: the Austrian ordinance is read in an unofficial consolidation (gesetzefinden.at), Italian art. 224 on Brocardi.it and ORS 459A.884 on Oregon.public.law; SPI has not yet confirmed these points against the official gazettes. Spanish RD 1055/2022 is read from its preamble; SPI has not yet confirmed the operative articles on publishing or reporting contributions.
  • Calculations: lead times are calendar days from the earliest public date SPI could find to the first day of application. The UK scenario uses percentages only and the assumptions in the Exhibit 10 note. No figures are converted or compared across currencies, and no rates are restated: for rates, see SPI’s per-tonne comparison and composite fee piece.
  • Not yet confirmed: who approves each year’s tables in Spain, Portugal and the Netherlands; whether Colorado’s annual dues update needs CDPHE approval; whether Recycle BC’s board formally adopts each schedule; Citeo’s and Repak’s 2027 rates; how PackUK treats tonnage without a RAM rating. Nothing here is legal advice.

FAQ

How are EPR fees calculated?

Most schemes start with a budget for collecting, sorting and recycling each packaging material, subtract what the sorted material sells for, add administration and reserves, and divide by the tonnes producers report. The result is a rate per kilogram or tonne for each material, which modulation then raises or lowers by recyclability, design or recycled content.

Who sets extended producer responsibility fees?

In 12 of the 14 markets SPI tracks, the producer responsibility organisation sets the yearly schedule, often after a board vote. In the UK, PackUK, the government’s scheme administrator, calculates fees. On the Isle of Man the plastic packaging tax rate follows UK law. Regulators usually approve the plan or licence rather than each rate.

Do regulators approve EPR fee schedules?

Usually they approve the method, not the number. Oregon, Colorado and British Columbia approve programme plans that carry fee rules. Belgium, Austria, France and Ireland add a check before fees apply, such as ministry notice with an auditor’s opinion. In Italy, the Netherlands, Spain, Portugal and Luxembourg, the scheme’s own board or assembly decides.

What costs do EPR fees cover?

EU law requires fees to cover separate collection, transport and treatment, information to consumers and data reporting, net of material and deposit revenue, and not to exceed the cost of a cost-efficient service. Colorado requires 100% of providers’ net recycling costs and caps administration at 5% of dues. The UK covers council disposal costs.

When are EPR fees published each year?

Most European schemes publish in September or October for the next January, and Ecoembes as early as summer. CAA published its 2027 Oregon and Colorado schedules on 1 October 2026 and Recycle BC on 21 October. PackUK issues UK year 2 notices by the end of November 2026, eight months into the fee year.

Can EPR fees change during the year?

Yes, in some schemes. ARA can change tariffs at the start of any month, ideally with a month’s notice, and partners can terminate after an increase. CONAI can change values on 1 January, 1 July or 1 October, and raised plastic from 1 October 2026. Citeo can revise rates if regulation changes.

Sources

  1. EUR-Lex: Directive 2008/98/EC, consolidated text of 5 July 2018, Article 8a, https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:02008L0098-20180705, consulted 2026-11-03.
  2. legislation.gov.uk: SI 2024/1332, regulation 60, https://www.legislation.gov.uk/uksi/2024/1332/regulation/60/made, consulted 2026-10-14.
  3. GOV.UK (PackUK): Producer disposal fees modulation statement, https://www.gov.uk/government/publications/extended-producer-responsibility-for-packaging-modulated-disposal-fees/packuk-extended-producer-responsibility-epr-for-packaging-producer-disposal-fees-modulation-statement, consulted 2026-11-03.
  4. GOV.UK (PackUK): Year 2 illustrative waste disposal fees (updated 19 December 2025), https://www.gov.uk/government/publications/illustrative-waste-disposal-fees-2026-extended-producer-responsibility-for-packaging/year-2-illustrative-waste-disposal-fees-extended-producer-responsibility-for-packaging, consulted 2026-10-14.
  5. GOV.UK: PackUK operational plan 2026 to 2027 (updated 10 August 2026), https://www.gov.uk/government/publications/packuk-operational-plan/packuk-operational-plan-2026-to-2027, consulted 2026-10-14.
  6. Colorado General Assembly: HB22-1355, signed act, https://content.leg.colorado.gov/sites/default/files/2022a_1355_signed.pdf, consulted 2026-11-03.
  7. ORS 459A.884, membership fee requirements (Oregon.public.law), https://oregon.public.law/statutes/ors_459A.884, consulted 2026-11-03.
  8. Circular Action Alliance: 2025 Oregon Producer Fee Schedule Explained (CAA-401, 29 May 2025), https://wineinstitute.org/wp-content/uploads/2025/07/401_Oregon_Fee_Setting_Explained_1_May2025_1_.pdf, consulted 2026-10-14.
  9. Circular Action Alliance: 2026 Oregon Producer Fee Schedule (published 29 October 2025), https://static1.squarespace.com/static/64260ed078c36925b1cf3385/t/693b2c9103be112d168e1b19/1765485713621/OR+2026+Fee+Schedule+Public.pdf, consulted 2026-10-14.
  10. B.C. Government: Recycle BC plan (19 August 2025) and approval (17 September 2025), https://www2.gov.bc.ca/assets/gov/environment/waste-management/recycling/recycle/residential-packaging-and-paper-recyclebc/recyclebc_plan_and_approval_2025.pdf, consulted 2026-10-14.
  11. Recycle BC: Fee schedule page, https://recyclebc.ca/producers/reporting-fees/fee-schedule/, consulted 2026-11-03.
  12. Fost Plus: Packaging EPR rates, what, why and how, https://www.fostplus.be/en/media/2252/download, consulted 2026-11-03.
  13. Repak: Approval as a packaging compliance scheme, 2026 to 2035, https://repak.ie/images/uploads/downloads/Repak_Approval_2026_to_2035.pdf, consulted 2026-11-03.
  14. Citeo: Fiche réflexe, instances de gouvernance (18 February 2025), https://bo.citeo.com/sites/default/files/2025-08/250218_CITEO_FICHE%20REFLEXE_INSTANCES_DE_GOUVERNANCE.pdf, consulted 2026-11-03.
  15. Citeo: Avis du Comité des Parties Prenantes (8 June 2026), https://www.citeo.com/wp-content/uploads/2026/06/8-juin-2026-Avis-du-Comite-des-Parties-Prenantes-de-la-filiere-des-emballages-menagers-et-papiers-graphiques-de-Citeo.pdf, consulted 2026-11-03.
  16. AIDA (INERIS): Arrêté du 5 septembre 2025 fixant les modulations applicables aux contributions financières, https://aida.ineris.fr/reglementation/arrete-050925-fixant-modulations-applicables-contributions-financieres-versees, consulted 2026-11-03.
  17. Citeo: Guide du tarif des emballages ménagers 2026 (updated 22 June 2026), https://clients-cms.citeo.com/uploads/guide_du_tarif_des_emballages_menagers_2026_f9e4c5b4e6.pdf, consulted 2026-10-14.
  18. Brocardi.it: D.Lgs. 152/2006, art. 224 (unofficial text), https://brocardi.it/codice-dell-ambiente/parte-quarta/titolo-ii/art224.html, consulted 2026-11-03.
  19. CONAI: Imballaggi in plastica, definiti i nuovi valori del Contributo ambientale CONAI (25 May 2026), https://www.conai.org/news-e-press/imballaggi-in-plastica-definiti-i-nuovi-valori-del-contributo-ambientale-conai/, consulted 2026-11-03.
  20. Verpact: Tarieven, https://www.verpact.nl/nl/tarieven, consulted 2026-11-03.
  21. BOE: Real Decreto 1055/2022, de envases y residuos de envases, https://www.boe.es/buscar/act.php?id=BOE-A-2022-22690, consulted 2026-11-03.
  22. Verpackungsverordnung 2014, § 9 and § 13 (unofficial consolidation), https://gesetzefinden.at/bundesrecht/verordnungen/20008902/para-9, consulted 2026-11-03.
  23. Ministry of the Environment, Luxembourg: Agrément REP N° 1/AG-EMBAL/23 (Valorlux), https://environnement.public.lu/content/dam/environnement/documents/offall_a_ressourcen/rep-zigaretten/0230213-valorlux-agrment-rep-n-1-ag-embal-23-1.pdf, consulted 2026-11-03.
  24. Ontario ERO notice 026-1058 (27 October 2026), https://ero.ontario.ca/notice/026-1058, consulted 2026-11-03.
  25. SPI fee-market files (14 markets), with the scheme tables, general terms and reports cited in the text (CAA 2026 Colorado schedule, SPV Tabela VPV 2026, Valorlux 2026 tariff and general conditions, Ecoembes Precios 2026 and eco-modulation guide, Repak QF 509, ARA general terms, Isle of Man Treasury notice of 3 March 2026), and SPI Packaging Regulation Tracker, /data/packaging-regulation-tracker/, consulted 2026-10-14.

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  1. Q1

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    We map each market's EPR, tax, ban, recycled-content, labelling and deposit rules against your materials and formats, and show which are in force, adopted or only proposed.

  2. Q2

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    We apply published fee tables and tax rates to your tonnages and recycled content, and show the result as scenarios with every rate sourced.

  3. Q3

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