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

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 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.

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.

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).

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.

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.

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.

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). 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). 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).

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.

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.