Luxembourg packaging EPR fees 2026

Luxembourg's packaging rules sit in the amended law of 21 March 2017 on packaging and packaging waste, read with the amended waste law of 21 March 2012 and the plastics law of 9 June 2022⁴. The Administration de l'environnement guide of December 2025 explains that any company placing packaging or a packaged product on the Luxembourg market for the first time is concerned, citing Article 3 point 16 of the 2017 law, whether it is the manufacturer, the importer or the distributor³. Transport packaging is non-household packaging under Article 3 point 8 and remains subject to the law even though the guide addresses household sales and grouping packaging³.

Valorlux is the only approved body for household packaging. Its current approval, Agrément REP N° 1/AG-EMBAL/23, was signed by the environment minister on 31 January 2023 after an application of 28 July 2022, runs for five years from notification, and rests on Article 19 of the waste law and Articles 6, 6bis and 8 of the packaging law⁴. Its scope covers household packaging and reusable household packaging, plus non-household packaging of seeds, pesticides and fertilisers used professionally in farming, wine growing and horticulture (Article 1(3))⁴.

Member contributions must at least cover the costs the law places on producers, and since 31 December 2024 Valorlux also carries costs under the 2022 plastics law, including single-use plastic awareness campaigns capped at EUR 100,000 a year including VAT (Articles 4(1), 4(3) and 7(1))⁴. The approval sets a 77% collection rate for PET bottles by 2025 (Article 8(5))⁴.

Valorlux publishes a Green Dot tariff each autumn for the following year, approved at its general assembly: the 2026 detailed table is marked GV October 2025 and the 2025 table GA October 2024¹². Rates are in euro per kilogram excluding VAT and run from PV00 reusable packaging at zero to PV15 other non-recyclable packaging at EUR 1.4830/kg¹. Article 4(2) of the approval requires contributions to be modulated by quantity, durability and repairability, reuse potential, recyclability, recycled content, hazardous substances and collection and recovery costs, so the codes split PET by colour and opacity and separate recyclable from non-recyclable plastics⁴.

The board sets a minimum contribution that cannot exceed EUR 125, and members pay quarterly advances of one quarter of the annual amount within 10 days of invoice, adjusted later by a complementary invoice or credit note (articles 5.3 and 5.4 of the general conditions)⁵. Members with an annual contribution below EUR 500 are billed once a year in the fourth quarter⁵.

SPI calculation: the annual contribution is EUR 2,653.88 excluding VAT¹. Because it exceeds EUR 500, Valorlux bills it as four quarterly advances of EUR 663.47, each payable within 10 days of invoice, and settles any difference after the 28 February declaration⁵.

Cartons carry 52.9% of the bill. Shrink film weighs 4.2% of the total but costs EUR 0.712/kg, 18 times the EUR 0.0389/kg paid for the trays beneath it. On the 2025 table the same four lines would have cost EUR 2,508.02: the HDPE line rose by EUR 195.30 on a 27.0% rate increase, while cartons, film and trays all became slightly cheaper².

Valorlux runs on one detailed annual declaration and quarterly advances, under its general conditions (version V.3)⁵. Valorlux's own reporting to the state follows dates set in the approval⁴.

Comparing the 2025 and 2026 Valorlux detailed tables shows a sharp rise for coloured and opaque PET and for HDPE, with small cuts elsewhere¹². PET bottles in other colours rose 60.3% to EUR 0.4857/kg and opaque PET 58.9% to EUR 0.4871/kg, colourless PET 27.6% to EUR 0.2498/kg, and HDPE 27.0% to EUR 0.3058/kg. Steel rose 46.1% to EUR 0.0396/kg and PV14 other recoverable 23.8% to EUR 1.3973/kg.

Rigid PP fell 16.9% to EUR 0.4279/kg, and paper, beverage cartons, PE films and rigid PS each fell by about 1% to 3%. The 2026 table also adds a separate PV14d line for PET trays. Neither table states the reason for the changes, and SPI has not found a Valorlux explanation, so none is given here.