# Belgium charges a non-recyclable pack 12 times a clear PET bottle, Luxembourg about 6 times, and both tables rise in 2027

> On the same 100-tonne household packaging basket, Fost Plus charges EUR 42,040.90 in 2026 and Valorlux EUR 17,117.60, both in euro excluding VAT; on the published 2027 tables the Belgian bill rises 3.5% and the Luxembourg bill 15.9%, so the gap narrows from 2.46 times to 2.19 times.

Publisher: Strategic Packaging Insights  
Published: 2026-10-26  
Last updated: 2026-10-26  
Page: https://www.strategicpackaginginsights.com/insights/benelux-packaging-fees-fost-plus-valorlux/

**On the same 100-tonne household packaging basket, Fost Plus charges EUR 42,040.90 in 2026 and Valorlux EUR 17,117.60, both in euro excluding VAT; on the published 2027 tables the Belgian bill rises 3.5% and the Luxembourg bill 15.9%, so the gap narrows from 2.46 times to 2.19 times.**

Belgium and Luxembourg share a currency, a border and many of the same products, but their packaging schemes price recyclability in different ways. Fost Plus sets a single non-recyclable rate at least double its dearest recyclable line, while Valorlux keeps its non-recyclable line close to its catch-all recoverable line and adds steep 2027 rises on glass, steel and cartons.

## Executive summary

Fost Plus in Belgium and Valorlux in Luxembourg are the two household packaging schemes of the Benelux that publish full per-kilogram tables in euro, and both have now put out their 2027 rates: Fost Plus on its Packaging EPR rates page and Valorlux on 13 October 2026, after its general assembly. Because both bill in euro, a brand selling into both markets can compare the bills line by line, which is rare in EPR.

The size of the gap is the first finding. SPI priced one 100-tonne household basket through both tables. At 2026 rates the Belgian bill is EUR 42,040.90 and the Luxembourg bill EUR 17,117.60, 2.46 times apart. On the 2027 tables, Fost Plus rises 3.5% to EUR 43,500.90 and Valorlux 15.9% to EUR 19,837.50 (Exhibit 9).

The second finding is fee design. Fost Plus prices every non-recyclable, valorised or obstructive pack at EUR 4.4190 per kg, a rate it says is at least double its highest recyclable rate, and keeps it unchanged for 2027. Valorlux's non-recyclable line (PV15, EUR 1.4830 per kg in 2026) is only 6% above its catch-all recoverable line (PV14). On the SPI basket, swapping 2 tonnes of non-recyclable pouches for mono PE film saves EUR 6,677.20 in Belgium and EUR 1,542.00 in Luxembourg (Exhibit 10).

The legal frames differ too. Belgium runs on a cooperation agreement between its three regions, overseen by the Interregional Packaging Commission (IRPC), with Fost Plus for household and Valipac for industrial packaging. Luxembourg runs on its amended law of 21 March 2017, with Valorlux approved by the minister on 31 January 2023, and a further bill (8482) still before parliament. Belgium added a separate litter levy in 2026 worth EUR 102 million a year.

For leaders, the practical message is threefold. Budget 2027 now, because both tables are public. Treat Belgium as the market where a non-recyclable pack is most expensive, so redesign pays most there. And map each pack to a likely PPWR recyclability grade before 2030, because Fost Plus already presents grade-based contributions from 2030 as part of the timeline.

## Key findings

1. **SPI calculation:**  the same 100-tonne household basket costs EUR 42,040.90 at Fost Plus and EUR 17,117.60 at Valorlux in 2026, and EUR 43,500.90 against EUR 19,837.50 on the 2027 tables, all excluding VAT.
2. Fost Plus's non-recyclable rate of EUR 4.4190 per kg is 12.3 times its clear PET bottle line and 2.0 times its PP film line in 2026; Valorlux's PV15 line of EUR 1.4830 is 5.9 times its clear PET line and 1.06 times PV14 (Fost Plus rates page; Valorlux 2026 table).
3. Valorlux's 2027 table raises glass 46.8%, steel 51.3%, beverage cartons 36.7% and HDPE 23.4%, while Fost Plus holds glass, paper, cartons, clear PET and the non-recyclable rate flat and raises steel 77.6% (both tables, consulted 23 October 2026).
4. Valipac charges Belgian industrial packaging EUR 20 per tonne for paper, metal, glass and other recyclable materials, EUR 63 for recyclable plastic and EUR 126 for non-recyclable materials in 2026, against EUR 14.50 and EUR 39.50 per tonne on Valorlux's industrial lines (Valipac version 12/2025; Valorlux 2026).
5. The IRPC's 2025 annual report says the working group set up to write Belgian eco-modulation rules for Green Dot rates was suspended at the end of 2025, with the PPWR now expected to cover fee modulation.
6. **SPI analysis:**  13 of the basket's 29 plastic tonnes sit on lines that both schemes price above their core streams, and the 2 tonnes on the penalty lines map onto the packs most exposed to the PPWR's grade C floor from 2030 at the earliest (Exhibit 11).

## Two schemes, one currency

The Benelux offers a clean comparison because Belgium and Luxembourg both price household packaging in euro per kilogram excluding VAT, and both publish a detailed declaration table with one rate per material category. The Netherlands, through Verpact, completes the trio; SPI's [EPR fees per tonne piece](https://www.strategicpackaginginsights.com/insights/epr-fees-per-tonne-2026/) prices Verpact alongside 11 other schemes, and this article keeps the Dutch scheme to context.

Fost Plus is the approved body for household packaging in Belgium. The IRPC granted its current accreditation on 2 February 2024, valid from 1 January 2024 to 31 December 2028 (IRPC, main points of the accreditation). Valorlux is the approved body for household packaging in Luxembourg, under ministerial approval REP N° 1/AG-EMBAL/23 dated 31 January 2023 and valid for five years from notification (Article 1(7) of the approval).

Both schemes set rates on cost. Fost Plus bases each rate on the real cost deficit of recycling that material: the budgeted cost of collection, sorting and recycling, minus revenue from selling the material, divided by declared tonnage (Fost Plus, Packaging EPR rates, what, why and how). Its board approves the rates in June and sends them with the method to the IRPC. Valorlux's approval requires contributions to be modulated by quantity, durability and repairability, reuse potential, high-quality recyclability, recycled content, hazardous substances and collection and recovery costs (Article 4(2) of the approval).

Exhibit 2 sets the main 2026 lines side by side in euro per tonne.

Two points stand out. The gap is widest on the heavy, cheap materials (glass, steel, paper), where Valorlux's rates are a fifth to a quarter of Belgium's. And it is narrowest on clear PET bottles, PET trays and PE films, where Valorlux charges two thirds of the Belgian rate. A pack mix heavy in glass and board therefore shows the largest Belgian premium.

Luxembourg also publishes PV00, reusable packaging, at EUR 0.0000 per kg, and PV14c, hazardous products, at EUR 1.7580 per kg in 2026, which is above its PV15 non-recyclable line (Valorlux 2027 table, 2026 column). Belgium prices hazardous household waste packaging at EUR 1.3784 per kg in 2026 (Fost Plus rates page).

## The 2027 tables are already out

Both schemes have now published 2027. Fost Plus sets its 2026 and 2027 rates side by side on its Packaging EPR rates page, and Valorlux's 2027 detailed table, marked AG octobre 2026, carries 2025, 2026 and 2027 columns. Exhibit 3 shows the change inside each scheme.

The directions differ. Fost Plus moves a few lines sharply, with steel up 77.6% and EPS and cork up 57.2%, while coloured PET bottles fall 17.7% and thick aluminium 18.7%. Valorlux moves almost everything up, so its 2027 table is a broad repricing rather than a targeted one. Neither Valorlux table states a reason for the changes, and SPI has not yet confirmed a Valorlux explanation.

Fost Plus gives its reasons for 2026 as higher collection and sorting costs, swings in material prices and contract renewals, plus investment in recycling post-sorted residual waste (Fost Plus, 24 September 2025). From declaration year 2026 it also books financial reserves per material, so they can smooth large swings for each material, which helps explain why five 2027 lines are flat.

SPI analysis

The 2027 tables push the two schemes closer together on paper and glass in relative terms, but Belgium's absolute rates stay higher on every matched line. On glass, the gap narrows from 5.18 times to 3.53 times; on clear PET bottles from 1.44 to 1.31 times. A brand that sells the same packs in both markets should expect the Luxembourg share of its Benelux EPR budget to grow in 2027.

## How each scheme prices recyclability

Neither scheme publishes a percentage bonus or malus on top of its rates, of the kind Citeo or Ecoembes apply. Eco-modulation in both is built into the categories: colour, opacity, polymer, gauge and a penalty line for packs that cannot be recycled. Exhibit 4 measures each lever as a ratio inside one scheme, so it compares design pressure without comparing price levels.

**The non-recyclable penalty.**  Fost Plus applies one rate to all non-recyclable household packaging, set at no less than twice its highest recyclable rate, and shares the extra income across the recyclable materials in line with their recycling percentages (Fost Plus, what, why and how). In 2026 the rate of EUR 4.4190 per kg is exactly 2.0 times its PP and other film line of EUR 2.2095. The rule holds against the material lines; the PPWR capsule lines added from 12 August 2026 sit closer, with plastic capsules at EUR 3.8414 per kg, 87% of the non-recyclable rate, falling to EUR 2.3519 in 2027. Since 1 January 2026, all obstructive packaging pays it without exception, because the last IRPC derogations expired on 31 December 2025 (Fost Plus, 24 September 2025).

The Belgian penalty line is broad. The 2026 table lists valorised items such as compostable plastics and wood, non-valorised items such as composite glass and ceramics, and obstructive packaging such as laminated plastic drink packaging with aluminium foil (D002) and black glass bottles coloured in the mass (D014), all at EUR 4.4190 per kg. Code 014-03 covers rigid and flexible elements made of PVC, PVdC, PETG and PET GAG (Fost Plus Green Dot rates 2026).

Valorlux has two lines at the top. PV14, other recoverable packaging, is EUR 1.3973 per kg in 2026 and PV15, other non-recoverable packaging, EUR 1.4830. A pack that falls outside the named streams therefore pays almost the same whether or not it is recoverable, and the real step is from a named stream into PV14. PE film to PV15 is 2.08 times; clear PET bottle to PV15 is 5.94 times.

**Colour and format.**  Both schemes split PET bottles by colour and opacity, but Belgium prices colour harder: a coloured PET bottle pays 3.49 times a clear one in 2026, against 1.94 times in Luxembourg. For 2027 the Belgian ratio eases to 2.87 times while the Luxembourg ratio rises to 2.08 times, so the two schemes move toward each other. Both price PET trays at a little over three times PET bottles, which reflects the weaker recycling chain for trays.

**Other surcharges.**  Fost Plus adds 15% when a member uses the fixed-price per-unit declaration and 10% when it uses the e-commerce parcel declaration (Fost Plus Green Dot rates 2026). These are process surcharges, not design maluses, but they raise a bill by a fixed share whatever the pack. Valorlux's general conditions add a contractual penalty equal to the evaded contributions if a false declaration is found (article 7.2, version V.3).

The Belgian eco-modulation debate is now on hold. The IRPC's 2025 annual report says the materials working group set up to write Belgian eco-modulation rules was suspended at the end of 2025, because the PPWR will now address the modulation of producers' contributions. For now, Belgian modulation stays inside the rate categories set by Fost Plus.

## Belgium: the cooperation agreement, the IRPC and Valipac

Belgium regulates packaging through the interregional cooperation agreement of 4 November 2008 between the Flemish, Walloon and Brussels-Capital regions. The amending agreement signed on 5 March 2020 was published in the Moniteur belge on 15 July 2020 and entered into force on 3 September 2020 (Wallex). It made foreign distance sellers to Belgian consumers packaging responsibles, required them to appoint a Belgium-based authorised representative in writing before placing products on the market, and set household plastic recycling targets of 65% from 2023 and 70% from 2030.

The 2020 text also links contributions to design. Its Article 9 rewrites the rule on how approved bodies calculate contributions per packaging material, adding recyclability and the presence of hazardous substances as factors, alongside durability, repairability and reuse potential (Wallex). That is the legal hook for Fost Plus's colour, polymer and non-recyclable lines.

The IRPC sits at the centre. Its own description makes it responsible for compliance with the cooperation agreement; it also approves or rejects companies' prevention plans, grants or refuses accreditation to the approved bodies, and since 1 January 2015 has also acted as Belgium's waste transit authority (IRPC, function page). Exhibit 5 sets the Belgian and Luxembourg frames side by side.

Reporting is the IRPC's main lever over companies. Its reporting page says every company placing packaged products on the Belgian market must report each year on the quantity, type and recycling rate of its packaging, either through Fost Plus for household and Valipac for industrial and commercial packaging, or directly through the IRPC's online declaration where the company is responsible only for type C packaging or runs its own take-back. A company whose packaging reaches both households and businesses must join both bodies (IRPC, reporting obligation).

The IRPC's accreditation of Fost Plus sets targets beyond recycling: at least a 25% increase in out-of-home collection by 2028 against 2024, a programme to raise the market share of reusable packaging by at least 5%, an absolute 5% cut in one-way packaging placed on the market, and at least 2% of the 2024 budget spent each year on avoidance and reuse (IRPC, main points, 2 February 2024). The IRPC approved Fost Plus's prevention, reuse and eco-design action programmes at the end of 2025 (IRPC annual report 2025).

Sanctions in the amended agreement are set per tonne. Article 12 of the 2020 text puts the general administrative fine at EUR 3,636.25, EUR 727.25 for each tonne not recovered and EUR 1,454.50 for each tonne not recycled, with caps and a doubling for repeat offences within three years (Wallex). The IRPC's sanctions page, consulted on 23 October 2026, still gives older per-tonne amounts of EUR 500 and EUR 1,000, so SPI uses the published amended text.

In practice: Valipac.

Valipac is Fost Plus's sister body for industrial packaging. Its 2026 contributions, version 12/2025, are EUR 20 per tonne for paper and board, metal, glass, natural fibres, wood and other recyclable materials, EUR 63 for recyclable plastic, EUR 126 for non-recyclable materials and zero for reusable packaging, with a minimum of EUR 50 and a fixed retroactive contribution of EUR 250 or EUR 100 for companies joining late. Fost Plus and Valipac reported 726,000 tonnes of business packaging recycled in 2025 (Fost Plus, 30 June 2026).

**SPI calculation:**  on this 50-tonne industrial mix, Valipac charges EUR 2,175 (EUR 43.50 per tonne) and Valorlux EUR 1,225 (EUR 24.50 per tonne). Industrial fees are an order of magnitude below household fees in both countries: Valipac's top rate of EUR 126 per tonne is 2.9% of Fost Plus's household non-recyclable rate. Valorlux's industrial lines are unchanged in the 2027 table.

## The Belgian litter levy

Since 2026 Belgian producers of litter-prone single-use packaging pay a second charge, collected by Fost Plus on top of the Packaging EPR contribution. Fost Plus says the levy transposes the Single-Use Plastics Directive (EU) 2019/904, that Belgium transposed the 2019 Directive only in 2026, and that the three regions set a total of EUR 102 million a year to be shared among producers. Fost Plus states on the same page that it has challenged the underlying cooperation agreement before the Constitutional Court (Fost Plus, EPR Litter).

The levy changes the Belgian comparison for food-to-go and drink brands. A non-recyclable plastic-containing food wrapper pays EUR 4,419 per tonne in Packaging EPR plus EUR 2,458.10 in litter levy, so the combined rate is EUR 6,877.10 per tonne before VAT. Fost Plus said the first advance invoice, for half of the estimated 2026 contribution, would arrive in October 2026, with a second at the start of 2027 (Fost Plus, EPR Litter).

SPI analysis

The litter levy also carries its own design signal. Flexible plastic food packaging pays 4.2 times rigid plastic food packaging, and non-recyclable plastic-containing packaging 7.5 times, so it reinforces the same ladder as the Packaging EPR table. Luxembourg handles single-use plastic costs differently: since 31 December 2024 Valorlux carries certain costs under the 2022 plastics law, with awareness campaigns capped at EUR 100,000 a year including VAT (Article 7(1) of the approval).

## Luxembourg: the 2017 law, the 2022 amendments and bags

Luxembourg's packaging rules sit in the amended law of 21 March 2017 on packaging and packaging waste. The Administration de l'environnement's guide of December 2025 says the packaging responsible is whoever first places packaging or packaged products on the Luxembourg market, citing Article 3 point 16 of the law, and that contributions are adjusted to the environmental impact of the packaging, with lower contributions for reusable, recyclable or lighter packs (AEV guide, December 2025).

Parliament amended the packaging law in 2022 as part of the waste package voted on 27 April 2022, alongside a new waste law and the law of 9 June 2022 on reducing the impact of certain plastic products. The ministry's presentation of 17 May 2022 lists the packaging measures and dates shown in Exhibit 8, and its press page adds that the packaging law creates the legal base for a deposit system in Luxembourg, with the details left to a grand-ducal regulation.

**Bags.**  Since 31 December 2018, single-use plastic bags thicker than 15 microns can no longer be given away free at points of sale, with an exception for very thin bags needed for hygiene or used as primary packaging for loose food (Portail de l'environnement, 27 December 2018). The May 2022 presentation lists bags of any material or size as payable at points of sale from 1 January 2025. Bill 8482, filed in 2025, would restate the rule so that from 1 January 2026 no bag with handles may be supplied free, with the price shown separately at the point of sale (bill 8482, government amendments of 22 December 2025).

**Reuse.**  The 2022 package requires restaurants to serve on-site consumption in reusable containers from 1 January 2023, and take-away and delivered meals to be offered in reusable containers with a return system from 1 January 2025, after a roadmap due by 1 January 2024 (ministry presentation, 17 May 2022). Bill 8482 as filed would have added a duty from 1 January 2027 to accept customers' own containers and reuse shares for take-away packaging of 10% by 2030, 20% by 2035 and 40% by 2040. The government amendments of December 2025 removed the take-away and refill provisions after the Conseil d'État's objections; SPI has not yet confirmed whether the reuse shares were removed with them.

**Produce.**  The ministry's press page says the rule requiring fruit and vegetables to be displayed without plastic packaging was relaxed and its start moved to align as closely as possible with French rules. Bill 8482 would let produce in plastic packaging be sold until 31 December 2025 to clear stock and would exempt lots of 1.5 kg or more and the items in an annex. SPI has not yet confirmed the consolidated date now in force.

**Fee modulation in the new bill.**  The December 2025 amendments reword the modulation duty in the 2017 law so that contributions take account of durability, repairability, reuse potential and recyclability. The Conseil d'État's supplementary opinion of 5 May 2026 asks for that generic list to be replaced with an explicit reference to Regulation (EU) 2025/40, failing which it would formally oppose the amendment. That is the clearest sign that Luxembourg's fee criteria will be tied to the PPWR text.

In practice: Valorlux.

Valorlux's 2025 annual report factsheet, announced on 9 October 2026, records 1,662 member companies, 69,660 tonnes of household packaging declared, 59,048 tonnes of household packaging placed on the market after adjustment for imports and exports, and a household packaging recycling rate of 81.13% against a legal minimum of 65%. Its approval sets a collection target of 77% by weight for single-use plastic drink bottles by 2025 (Article 8(5)), and members file a detailed declaration by 28 February each year, with quarterly advances for contributions of EUR 500 or more (general conditions V.3, article 5.3).

## The worked basket, priced in both schemes

SPI built one household basket of 100 tonnes that a consumer goods brand might sell into both markets, and priced it line by line at each scheme's own 2026 and 2027 rates (Exhibit 9). The basket is an SPI assumption for comparison, not a market average, and it uses the detailed declaration in both schemes. Both bills are in euro, so they can be compared directly.

**SPI calculation:**  the Belgian bill is EUR 24,923.30 higher than the Luxembourg bill in 2026, or 2.46 times, and EUR 23,663.40 higher in 2027, or 2.19 times. Per tonne, that is EUR 420.41 against EUR 171.18 in 2026, and EUR 435.01 against EUR 198.38 in 2027.

Where the bill comes from differs too. The 29 tonnes of plastic, counting the non-recyclable multilayer, are 66.6% of the Belgian bill and 77.3% of the Luxembourg bill in 2026. The 2 tonnes of non-recyclable multilayer alone are 21.0% of the Belgian bill (EUR 8,838) and 17.3% of the Luxembourg bill (EUR 2,966). Glass and paper, 60 tonnes together, are 19.3% of the Belgian bill and 11.5% of the Luxembourg bill.

The 2027 increase also has different drivers. In Belgium, of the EUR 1,460 rise, steel adds EUR 723, PE films EUR 575.10 and PP rigid EUR 374.40, while coloured PET falls by EUR 444.40. In Luxembourg, of the EUR 2,719.90 rise, beverage cartons add EUR 618, HDPE EUR 357.50, PE films EUR 370.50 and the non-recyclable line EUR 276. A brand with a carton-heavy range feels the Luxembourg 2027 rise most.

SPI analysis

The Belgian premium is not the same on every pack, which matters for pricing and range decisions. On clear PET bottles it is EUR 110.60 per tonne in 2026, and on non-recyclable multilayer EUR 2,936 per tonne. A brand with mostly clear PET and paper sees a modest Belgian premium; a brand with laminates and coloured plastics sees a large one.

## Scenarios: redesign, base and downgrade

To show how much design moves each bill, SPI ran three cases on the same basket in each scheme and year (Exhibit 10). The low case is a redesign: the 2 tonnes of coloured PET bottles become clear, and the 2 tonnes of non-recyclable multilayer become mono PE film, at the same weight. The high case is a downgrade: the 3 tonnes of PE film become non-recyclable multilayer, for example by adding a metallised barrier.

**SPI calculation:**  in Belgium, the redesign saves EUR 8,470 in 2026, of which EUR 6,677.20 comes from moving the multilayer to PE film and EUR 1,792.80 from clearing the coloured PET. In Luxembourg the same redesign saves EUR 2,013.80, of which EUR 1,542 comes from the multilayer and EUR 471.80 from the PET. Per tonne of pack changed, a non-recyclable pack moved to PE film saves EUR 3,338.60 in Belgium against EUR 771 in Luxembourg.

The downgrade case is the mirror. Adding a non-recyclable barrier to 3 tonnes of PE film raises the Belgian bill by EUR 10,015.80 in 2026 and the Luxembourg bill by EUR 2,313. Because Fost Plus holds its non-recyclable rate flat for 2027 while PE film rises 17.7%, the Belgian downgrade costs a little less in 2027 (EUR 9,440.70) than in 2026.

SPI analysis

The redesign reward in Belgium is about four times the Luxembourg reward on the same tonnes, so a Benelux brand that prioritises redesign by market should start with the packs it sells in Belgium. For food-to-go items, the Belgian litter levy widens the reward further, since its own non-recyclable rate is 7.5 times its rigid plastic food rate.

## Mapping the tables onto PPWR recyclability grades

Regulation (EU) 2025/40 has applied since 12 August 2026, and Article 6(1) requires all packaging placed on the market to be recyclable ([PR-EU-010](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-010/)). The measurable test comes later: design for recycling from 1 January 2030, or 24 months after the Article 6(4) delegated acts if that is later, with recyclability expressed in grades A, B and C. Packaging below grade C is treated as technically non-recyclable, and from 1 January 2038 the floor rises to grade B (recital 28, via [PR-EU-010](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-010/)). Recital 35 says the grades will be used to modulate producer fees under harmonised criteria, without the Regulation setting the amounts.

Fost Plus's presentation of 20 March 2026 sets the grade thresholds at above 95% for A, above 80% for B and above 70% for C, measured as recyclability performance for the whole pack. It notes that packs under 70% are likely to be banned by 2030, and its timeline shows financing contributions based on grades A to C from 2030. The Commission is to propose the design-for-recycling criteria and grades by January 2028 (Fost Plus presentation; [PR-EU-010](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-010/)).

No pack has a PPWR grade yet, so SPI built a proxy ladder from each scheme's own categories (Exhibit 11). It groups lines by how the scheme already prices them, which is the closest available signal of how sortable and recyclable each format is in that country today.

The two schemes reach the PPWR from different starting points. Fost Plus already uses its penalty line as a bar on obstructive designs, listing them by code (D001 to D018), so its table is close to a ban-in-waiting for packs that will fall below grade C. Valorlux's PV14 and PV15 are only 6% apart, so its table does not yet separate recoverable packs outside the named streams from non-recoverable packs in price, which is the line the PPWR grades will draw.

SPI analysis

Three outcomes are possible once the grades exist, and they are not exclusive. A scheme can keep its material lines and add a grade overlay, re-cut lines around grades, or keep lines and let the 2030 floor remove grade-less packs. The IRPC's suspension of Belgian eco-modulation work and the Conseil d'État's call to anchor Luxembourg's criteria in Regulation (EU) 2025/40 both point to a common EU grade standard sitting under national rates. SPI has not yet confirmed any Fost Plus or Valorlux decision on how grades will enter their tables. Italy offers a parallel: the [CONAI fee bands piece](https://www.strategicpackaginginsights.com/insights/italy-conai-fee-bands-explained/) sets out how CONAI's bands may meet the same grades.

Labels are the nearer deadline. Fost Plus says the PPWR bars the Green Dot logo from packaging from 12 February 2027 (see Industry reaction), and it has renamed its Green Dot rates as Packaging EPR rates. Valorlux's 2027 table is still titled Les tarifs Point Vert 2027, which is a name for the tariff, not a logo on the pack.

In practice: Fost Plus.

Fost Plus and Valipac reported 827,000 tonnes of household packaging recycled in Belgium in 2025, alongside 726,000 tonnes of business packaging (Fost Plus, 30 June 2026). The IRPC's 2025 annual report says the expanded PMD stream is sorted entirely in Belgium, in six sorting plants, and that 72.7% of Fost Plus packaging waste is recycled in Belgium. Since 12 August 2026, Fost Plus has added PPWR categories for beverage capsules, pads, tea bags and fruit labels, with compostable pads and labels at EUR 0.6879 per kg and non-compostable ones at the non-recyclable rate.

## Industry reaction

> "This is at least double the highest rate for recyclable materials."

***Fost Plus** , Belgian household packaging body, [Packaging EPR rates, what, why and how](https://www.fostplus.be/en/media/2252/download), consulted 23 October 2026*

The sentence describes the single rate Fost Plus charges for non-recyclable packaging, which it holds at EUR 4.4190 per kg in both 2026 and 2027.

The Interregional Packaging Commission, Belgium's packaging regulator, says in its [annual report 2025](https://av25.ivcie.be/en/fost-plus/) that the materials working group first tasked with setting Belgian rules on the eco-modulation of Green Dot rates was suspended at the end of 2025, and that the PPWR will now address the modulation of producers' financial contributions.

> "Under the new European PPWR legislation, the Green Dot logo may no longer be used on packaging as of 12 February 2027."
>
>
>
> **Fost Plus** , Belgian household packaging body, [Packaging EPR rates](https://www.fostplus.be/en/members/green-dot-rates), consulted 23 October 2026
>
>
>
> "Les obligations qui incombent à tous les acteurs de la chaîne d'emballage sont indéniables."

In English: "The obligations on every actor in the packaging chain are undeniable."

***Verpact** , Dutch packaging scheme, its CEO (also President of EXPRA), quoted in [Valorlux's news release on six packaging organisations](https://www.valorlux.lu/fr/mission/actualites/article/17-10-2025/collaboration-six-organisations-emballages-plus-durable), 17 October 2025*

The release records a declaration of intent signed on 8 October 2025 by Fost Plus, Valipac, Verpact, Citeo, Citeo Pro and Valorlux to share packaging data, knowledge on sustainable packaging systems and work on industrial packaging, including a standard producer definition.

## What leaders should do now

1. **Finance and packaging leads, by 30 November 2026:**  load the published 2027 Fost Plus and Valorlux tables into 2027 budgets, line by line, and flag the Luxembourg carton, glass, steel and HDPE rises of 23% to 51%.
2. **Packaging development teams, before 2027 briefs are frozen:**  list every pack on Fost Plus's EUR 4.4190 line or Valorlux's PV14 and PV15 lines, and cost a recyclable alternative first for packs sold in Belgium, where the reward per tonne is about four times larger.
3. **Food-to-go and drink brands in Belgium, by the start of 2027:**  add the litter levy to unit costs, check the October 2026 advance invoice against your 2025 declaration, and model the combined Packaging EPR and litter rate for flexible and non-recyclable items.
4. **Compliance teams, by 28 February 2027:**  file the 2026 declarations to both schemes on the detailed basis, check that each component is declared under its own material, and confirm whether any industrial packaging belongs with Valipac or on Valorlux's PV16 to PV19 lines.
5. **Label and artwork owners, by 12 February 2027:**  remove the Green Dot logo from Belgian packaging artwork in line with Fost Plus's guidance, and check Luxembourg artwork on the same schedule.
6. **Sustainability teams, during 2027:**  map each pack to SPI's three-step ladder (Exhibit 11) and plan redesigns for step 3 packs ahead of the Article 6(4) delegated acts due by January 2028.
7. **Regulatory affairs, through 2027:**  track bill 8482 in Luxembourg, especially the bag, produce and fee-modulation provisions, and check with counsel before relying on any date not yet in force.

## Questions for your board

- What did we pay Fost Plus, Valorlux and Valipac in 2026, and what will the published 2027 tables add?
- How many tonnes do we place on Fost Plus's non-recyclable line, and what would a redesign save per tonne?
- Have we priced the Belgian litter levy into our food-to-go and drink ranges?
- Which of our packs sit in step 3 of the ladder, and are they on a redesign plan before the 2030 grade C floor?
- Is our Benelux artwork free of the Green Dot logo by 12 February 2027?
- Who owns tracking of Luxembourg bill 8482 and its effect on bags, produce and reuse?

## What to watch

- **Start of 2027:**  Fost Plus sends the second litter levy advance invoice for 2026 (Fost Plus, EPR Litter).
- **1 Jan 2027:**  the 2027 Fost Plus and Valorlux tables apply.
- **12 Feb 2027:**  the Green Dot logo may no longer be used on packaging, according to Fost Plus.
- **28 Feb 2027:**  Fost Plus and Valorlux declarations for 2026 are due.
- **1 Jan 2028:**  the Article 6(4) design-for-recycling delegated acts with recyclability grades are due ([PR-EU-010](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-010/)).
- **31 Dec 2028:**  Fost Plus's current IRPC accreditation ends.
- **1 Jan 2030:**  the PPWR design-for-recycling test applies at the earliest, with packs below grade C barred ([PR-EU-010](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-010/)).

## Methodology

- **Data used:**  Fost Plus's Packaging EPR rates page (2026 and 2027) and 2026 rate PDF; Valorlux's detailed tariffs for 2026 and 2027 (AG octobre 2026); Valipac's 2026 contributions; IRPC, Wallex, Luxembourg ministry, Administration de l'environnement and Chambre des Députés documents; SPI's Belgium and Luxembourg fee-market notes (14 October 2026) and rule [PR-EU-010](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-010/). Consulted 23 October 2026 unless stated.
- **Counting rules:**  EUR per tonne as published (EUR per kg x 1,000), excluding VAT, detailed declaration, before per-unit and e-commerce surcharges, minimum contributions and Belgium's litter levy unless stated. Each line is tonnes x rate. Both schemes bill in euro, so totals are compared in one currency.
- **Basket and scenarios:**  the 100-tonne household basket and the 50-tonne industrial mix are SPI assumptions, not market averages. Weights are held constant in the scenarios.
- **Ladder:**  the three steps are SPI's grouping of each scheme's own lines and are a proxy, not a PPWR grade.
- **Cut-off:**  23 October 2026.
- **Limitations:**  Fost Plus and Valorlux categories do not match one to one; Valorlux has no separate PP film or thin aluminium code; SPI has not yet confirmed a Valipac 2027 table or the adopted text of Luxembourg bill 8482. This is not an invoice or a legal view; confirm categories with each scheme and check with counsel where it applies.

## Sources

1. Fost Plus, Packaging EPR rates (2026 and 2027 table), [https://www.fostplus.be/en/members/green-dot-rates](https://www.fostplus.be/en/members/green-dot-rates), consulted 2026-10-23.
2. Fost Plus, Green Dot rates 2026 per material (EUR/kg), [https://www.fostplus.be/en/media/1930/download](https://www.fostplus.be/en/media/1930/download), consulted 2026-10-23.
3. Fost Plus, Packaging EPR rates, what, why and how, [https://www.fostplus.be/en/media/2252/download](https://www.fostplus.be/en/media/2252/download), consulted 2026-10-23.
4. Fost Plus, Everything you need to know about the Green Dot rates for 2026 (24 September 2025), [https://www.fostplus.be/en/blog/everything-you-need-to-know-about-green-dot-rates-for-2026](https://www.fostplus.be/en/blog/everything-you-need-to-know-about-green-dot-rates-for-2026), consulted 2026-10-23.
5. Fost Plus, Declaration, [https://www.fostplus.be/en/members/declaration](https://www.fostplus.be/en/members/declaration), consulted 2026-10-23.
6. Fost Plus, EPR Litter, [https://www.fostplus.be/en/members/epr-litter](https://www.fostplus.be/en/members/epr-litter), consulted 2026-10-23.
7. Fost Plus, PPWR, what will change for you (presentation of 20 March 2026), [https://www.fostplus.be/en/media/2108/download](https://www.fostplus.be/en/media/2108/download), consulted 2026-10-23.
8. Fost Plus, Fost Plus and Valipac, over 1.5 million tonnes of packaging recycled (30 June 2026), [https://fostplus.prezly.com/fost-plus-and-valipac-over-15-million-tonnes-of-packaging-recycled](https://fostplus.prezly.com/fost-plus-and-valipac-over-15-million-tonnes-of-packaging-recycled), consulted 2026-10-23.
9. Valipac, Overview of the funding contributions 2026 (version 12/2025), [https://www.valipac.be/wp-content/uploads/2025/12/en-funding-contributions-2026.pdf](https://www.valipac.be/wp-content/uploads/2025/12/en-funding-contributions-2026.pdf), consulted 2026-10-23.
10. Interregional Packaging Commission, Main points of the new accreditation of Fost Plus of 2 February 2024, [https://www.ivcie.be/wp-content/uploads/2024/06/Main-points-new-accreditation-Fost-Plus-2024.pdf](https://www.ivcie.be/wp-content/uploads/2024/06/Main-points-new-accreditation-Fost-Plus-2024.pdf), consulted 2026-10-23.
11. Interregional Packaging Commission, Annual report 2025, Fost Plus, [https://av25.ivcie.be/en/fost-plus/](https://av25.ivcie.be/en/fost-plus/), consulted 2026-10-23.
12. Interregional Packaging Commission, Function of the IRPC, [https://www.ivcie.be/en/function-of-the-irpc/](https://www.ivcie.be/en/function-of-the-irpc/); Reporting obligation, [https://www.ivcie.be/en/obligations/reporting-obligation/](https://www.ivcie.be/en/obligations/reporting-obligation/); Sanctions, [https://www.ivcie.be/en/obligations/sanctions/](https://www.ivcie.be/en/obligations/sanctions/), consulted 2026-10-23.
13. Wallex, Accord de coopération du 5 mars 2020 modifiant l'accord de coopération du 4 novembre 2008 concernant la prévention et la gestion des déchets d'emballages (Moniteur belge, 15 July 2020), [https://wallex.wallonie.be/nl/contents/acts/133/133121.html](https://wallex.wallonie.be/nl/contents/acts/133/133121.html), consulted 2026-10-23.
14. Valorlux, Grüner Punkt Tarife 2026, detaillierte Meldung (October 2025), [https://www.valorlux.lu/media/68e634367e399_gruener-punkt-tarife-2026-detailliert.pdf](https://www.valorlux.lu/media/68e634367e399_gruener-punkt-tarife-2026-detailliert.pdf), consulted 2026-10-23.
15. Valorlux, Les tarifs Point Vert 2027, déclaration détaillée (AG octobre 2026), [https://www.valorlux.lu/media/0d2fbf1a-de20-4f9a-9529-ca82c37ebcac/tarifs-point-vert-2027-detaille1.pdf](https://www.valorlux.lu/media/0d2fbf1a-de20-4f9a-9529-ca82c37ebcac/tarifs-point-vert-2027-detaille1.pdf), and news of 13 October 2026, [https://www.valorlux.lu/fr/mission/actualites/article/13-10-2026/les-tarifs-point-vert-pour-2027-declaration-detaillee](https://www.valorlux.lu/fr/mission/actualites/article/13-10-2026/les-tarifs-point-vert-pour-2027-declaration-detaillee), consulted 2026-10-23.
16. Valorlux, Rapport annuel 2025, factsheet (9 October 2026), [https://www.valorlux.lu/media/bd557501-e1ae-4fbd-9b77-da821be1a15d/val-2607062-rapport-annuel-2025-factsheet-fr.pdf](https://www.valorlux.lu/media/bd557501-e1ae-4fbd-9b77-da821be1a15d/val-2607062-rapport-annuel-2025-factsheet-fr.pdf), consulted 2026-10-23.
17. Valorlux, Six éco-organismes unissent leurs forces pour des emballages plus durables (17 October 2025), [https://www.valorlux.lu/fr/mission/actualites/article/17-10-2025/collaboration-six-organisations-emballages-plus-durable](https://www.valorlux.lu/fr/mission/actualites/article/17-10-2025/collaboration-six-organisations-emballages-plus-durable), consulted 2026-10-23.
18. Valorlux, Conditions générales, version V.3, [https://www.valorlux.lu/media/63c93eacd974d_conditions-generales-fr-v3.pdf](https://www.valorlux.lu/media/63c93eacd974d_conditions-generales-fr-v3.pdf), consulted 2026-10-23.
19. Ministère de l'Environnement, Agrément REP N° 1/AG-EMBAL/23 (Valorlux), 31 January 2023, [https://environnement.public.lu/content/dam/environnement/documents/offall_a_ressourcen/rep-zigaretten/0230213-valorlux-agrment-rep-n-1-ag-embal-23-1.pdf](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 2026-10-23.
20. Administration de l'environnement, guide REP emballages (December 2025), [https://environnement.public.lu/content/dam/environnement/documents/offall_a_ressourcen/emballages/aev-rep-guide-em-final.pdf](https://environnement.public.lu/content/dam/environnement/documents/offall_a_ressourcen/emballages/aev-rep-guide-em-final.pdf), consulted 2026-10-23.
21. Administration de l'environnement, Responsabilités des responsables d'emballages (version September 2022), [https://environnement.public.lu/content/dam/environnement/documents/offall_a_ressourcen/emballages/2022-rep-emballages-aev.pdf](https://environnement.public.lu/content/dam/environnement/documents/offall_a_ressourcen/emballages/2022-rep-emballages-aev.pdf), consulted 2026-10-23.
22. Portail de l'environnement, Les sacs en plastique gratuits, c'est bientôt fini (27 December 2018), [https://environnement.public.lu/fr/actualites/2018/12/sacs_en_plastique.html](https://environnement.public.lu/fr/actualites/2018/12/sacs_en_plastique.html), consulted 2026-10-23.
23. Ministère de l'Environnement, presentation of the Offall- a Ressourcëpak (17 May 2022), [https://environnement.public.lu/content/dam/environnement/actualites/2022/05/ppt-pk-offallgesetz-17052022.pdf](https://environnement.public.lu/content/dam/environnement/actualites/2022/05/ppt-pk-offallgesetz-17052022.pdf), and press page, [https://environnement.public.lu/fr/actualites/2022/05/offall-a-ressoucepak.html](https://environnement.public.lu/fr/actualites/2022/05/offall-a-ressoucepak.html), consulted 2026-10-23.
24. Chambre des Députés, bill 8482: bill as filed, [https://wdocs-pub.chd.lu/docs/Dossiers_parlementaires/8482/20250515_Depôt.pdf](https://wdocs-pub.chd.lu/docs/Dossiers_parlementaires/8482/20250515_Depôt.pdf); government amendments (22 December 2025), [https://wdocs-pub.chd.lu/docs/Dossiers_parlementaires/8482/20251222_AmendementGouvernemental.pdf](https://wdocs-pub.chd.lu/docs/Dossiers_parlementaires/8482/20251222_AmendementGouvernemental.pdf); Conseil d'État supplementary opinion, [https://wdocs-pub.chd.lu/docs/Dossiers_parlementaires/8482/20260720_Avis.pdf](https://wdocs-pub.chd.lu/docs/Dossiers_parlementaires/8482/20260720_Avis.pdf), consulted 2026-10-23.
25. EUR-Lex, Regulation (EU) 2025/40, recitals 28 to 35, and Commission Notice C/2026/3084, via SPI Regulation Tracker rule PR-EU-010, [https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202500040](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202500040), consulted 2026-10-14.