Composite packaging EPR fees: one laminate pouch is charged EUR 616 to EUR 4,419 a tonne in 2026

How composite packaging EPR fees are set in seven schemes

A fee table is a list of materials with a price per kilogram. A composite pack has to be mapped onto that list, and there are only a few ways to do it. Exhibit 2 records the rule each scheme publishes for a pack that cannot be separated by hand, the threshold it applies, and the line and 2026 rate the pack ends up on.

Austria routes by threshold. Annex 5 of the Verpackungsverordnung 2014 assigns a composite pack to the tariff category of its main material where that material is at least 80% of the packaging unit by weight, with beverage cartons on their own line, and sends plastic-based composites to the composite category when plastic is under 95% (VerpackVO Annex 5). ARA’s fact sheet of 24 November 2022 repeats the thresholds: 80% for paper, metals, glass, wood, ceramics, textiles and biodegradable materials, 95% for plastic. It also excludes combinations of materials of the same type, so a PE and PP laminate stays plastic. ARA’s examples of composites include blister packs, metal-coated coffee bags, cardboard boxes with an aluminium bag inside and paperboard tubes with a plastic base or lid (ARA fact sheet).

Belgium sorts by element, then by heaviest material. Fost Plus asks for every element of a pack to be declared under its own material, and gives a jar as the example: glass for the jar, paper-cardboard for the label and steel for the lid (Fost Plus 2026 rates). Where an element itself combines materials, the code follows the heaviest one. Composite elements led by glass (017) or steel (018), paper composites under 85% fibre that fail the CEPI recyclability protocol (012), and plastic laminates with an aluminium film (014-03) all pay the non-recyclable rate of EUR 4.4190 per kg.

France and the Netherlands split the pack. Citeo’s guide says the declaration per sales unit takes account of every packaging unit and every material in it, and each material family has its own tariff (Citeo guide 2026, pp. 25 and 27). Verpact defines a samengestelde verpakking as packaging of several material types that cannot be separated, and says the producer owes the fee on each material type and declares them separately (Beleid Verpact 2026, section 3.1.1). Neither publishes a main-material threshold.

Italy, Spain and Ireland each add a twist. CONAI routes a pack to the consortium of its prevalent material and then to a band, and its band lists put plastic-prevalent laminates (poliaccoppiati) of any shape or size in band C (CONAI band lists). Ecoembes identifies a main element, the heaviest hollow body or, failing that, the heaviest household packaging, and applies a single 10% surcharge to its base price when it is multimaterial, defined as two or more layers of different materials that cannot be separated by hand (Guía de ecomodulación 2026, pp. 6, 17 and 28). Repak’s training material says that if the main material weighs less than 95% of the overall weight, the item is reported as composite, and if more than 95%, all of it is reported as the main material (Repak QF 509).

The thresholds: 5% at the EU, 80% to 95% in the schemes

Thresholds are where a small change in a pack’s construction causes a large change in its fee. Exhibit 3 lists every numeric threshold in the documents SPI read that decides whether a multi-material pack is classed as one material or as a composite.

Two features stand out. First, the EU’s 5% line and the schemes’ 95% lines are the same test seen from opposite sides for plastic: a pack with 96% PE and 4% aluminium is single material for the PPWR, for ARA, for Repak and for Fost Plus’s film codes. Second, the 80% line at ARA is much looser than the EU’s 5%, so a paper pack with 18% plastic lining is single material in Austria’s tariff but composite under the PPWR definition. SPI analysis: the national lines are what decide the 2026 fee; the EU line decides which EU rules apply, notably the format bans and the recycled content exemption, so a brand needs both readings for each SKU.

Composite lines by year: 2025, 2026 and 2027

Exhibit 4 gathers the lines a composite most often lands on, with the year each rate applies to. Where a scheme has no composite line, the line its split or routing rule uses is shown.

The direction differs by scheme. ARA raised its household composite line 5.6% for 2026 and holds it for 2027, keeping the composite premium over plastic at EUR 100 a tonne (ARA tariff sheets). Fost Plus holds EUR 4.4190 for its non-recyclable codes for 2027, trims other plastic films 3.0% to EUR 2.1425 and raises multilayer PET trays 32.1% (Fost Plus rates page). CONAI’s band C rose 16.7% on 1 October 2026, which CONAI tied to higher quantities managed, collection and sorting costs, and weak demand for some recycled fractions, mainly in bands B2 and C (CONAI, 25 May 2026). Repak’s non-recycled composite rate rose with its non-recycled plastic rate, both to EUR 616.22 (Repak 2026 sheet).

What a composite pays above its main material

The cleanest measure of how hard a scheme leans on composites is the ratio, inside one scheme, between the line a laminate falls on and the line the same pack would pay if it were mono-material plastic. Exhibit 5 shows it.

Two groups appear. Fost Plus and Repak price a laminate at their non-recyclable level, 3.7 to 4.1 times the recyclable plastic line. The other five price it within 10% of plastic, except Citeo, where the complex resin line is 1.82 times PE but applies only to the plastic part of the pack. Ledger 49 showed the paper version of the same pattern, where Fost Plus prices a paper composite at 29.4 times plain board (paper and board fees); for plastic laminates the gap is smaller but the logic is identical.

A framework: four ways to classify a composite

The seven rules reduce to four archetypes, set out in Exhibit 6. Each archetype has a different lever, which is why the same redesign is worth a lot in one scheme and almost nothing in the next.

Four packs, seven schemes: the worked comparison

Exhibit 7 prices four constructions per tonne of pack in each scheme: a PET, aluminium and PE coffee pouch; a metallised OPP and PE snack film; a paper, PE and aluminium soup sachet; and a mono-material PE pouch with an EVOH barrier under 5%, which is the usual redesign target. The shares are SPI assumptions for illustration, not measurements of any product.

The working is short. SPI calculation: in France, 0.85 tonnes of plastic at EUR 1,400.10 plus 0.15 tonnes of aluminium at EUR 243.40 gives EUR 1,226.60 for the pouch, and the sachet is 0.7 tonnes of paper at EUR 258.10, 0.2 tonnes of PE at EUR 770.10 and 0.1 tonnes of aluminium at EUR 243.40, or EUR 359.03. In the Netherlands, 0.85 tonnes at EUR 1,320 plus 0.15 tonnes at EUR 340 gives EUR 1,173.00, and the sachet is EUR 11.90 for paper, EUR 264.00 for PE and EUR 34.00 for aluminium, or EUR 309.90. Austria routes both the pouch (85% plastic, under 95%) and the sachet (70% paper, under 80%) to the composite line at EUR 1,140. Fost Plus routes the pouch to 014-03 and the sachet to 012 as a paper-led composite under 85% fibre; aluminium-lined paper bags for powdered soups are also on its obstructive list (D016).

Three results run against intuition. The paper sachet is the cheapest construction in France, Italy and the Netherlands but among the dearest in Austria, Belgium and Ireland, because the first group splits or bands by fibre share and the second group routes the whole pack to a composite line. The Dutch split rewards aluminium, which costs a quarter of flexible plastic per kilogram, so the gross Dutch fee for a mono PE pouch is 12.5% above the laminate; Verpact’s design discount narrows that, because a mono-material flexible of at least 90% PE earns EUR 0.10 per kg off, taking it to EUR 1,220, still above the laminate (Regeling Tariefdifferentiatie Plastic 2026). And in Italy the four packs sit within EUR 155 to EUR 922, the narrowest plastic range of the seven.

The 5% barrier: when EVOH changes the line

Barrier layers are the most common reason a near mono-material pack becomes a composite. Exhibit 8 takes a PE pouch with an EVOH oxygen barrier and moves the EVOH share from 3% to 7% of weight.

The Belgian jump comes from a share, not a material. Fost Plus’s PE film code 011-07 needs at least 95% PE; a film with 7% EVOH drops into 011-09, other plastic films, at more than twice the rate (Fost Plus 2026 rates). At CONAI, the same 5% line moves the pack from B2.2 to band C. At Ecoembes, a multimaterial pack, including one with EVOH at 5% or more, is the first branch of the penalty decision tree, and the 10% surcharge also wipes out the flexible plastic bonus of up to 4.38% that the pouch might otherwise earn (Guía de ecomodulación 2026, pp. 28 and 31).

Scenarios: redesigning 100 tonnes of laminate in Belgium

Belgium is where the composite rule bites hardest, so the scenario is set there, in one currency. Exhibit 9 prices 100 tonnes of aluminium laminate pouches and three redesign paths, on the 2026 and 2027 Fost Plus tables.

The saving shrinks for 2027 because Fost Plus raises PE film 17.7% to EUR 1.2721 per kg while holding the laminate rate (Fost Plus rates page). Even so, the base case saves EUR 295,608.50 on the 2027 table by SPI’s calculation. For contrast, the same 100 tonnes in Italy would fall from EUR 92,200 in band C to EUR 85,600 in band B2.2, a 7.2% saving, and in Austria from EUR 114,000 to EUR 104,000, an 8.8% saving, at the same weight.

Separable parts: declare them, or pay for the whole

Many packs called composites are in fact assemblies: a glass jar with a steel lid, a paper tube with a plastic cap, a tray with a film lid. Whether the parts can be separated by hand decides whether they are priced apart.

All seven schemes price separable components on their own lines. Fost Plus says all packaging elements must be declared based on their material category (Fost Plus 2026 rates). Ecoembes does not penalise a paper composite that the consumer can separate by hand and that carries a separation message, and forced-removal accessories carry no penalty when they are labelled (Guía de ecomodulación 2026, pp. 19 and 28). Repak’s 95% rule and ARA’s 80% rule apply to the packaging unit; ARA’s fact sheet excludes combinations of packaging and packaging aids from the composite definition, provided they do not fall below its single-material thresholds (ARA fact sheet).

Bonded parts are where cost appears. Fost Plus’s obstructive list includes a plastic can with a metal bottom or top (D001) and laminated board packs for crisps or milk powder with a plastic or metal bottom or top (D003, D004), all at the highest rate and all requiring a detailed declaration (Fost Plus 2026 rates). CONAI places a bottle with glued or welded metal components in band C (CONAI band lists). Citeo applies a 100% malus to PET-majority rigid packs combined with aluminium, PVC or silicone denser than water (Citeo guide 2026, p. 40).

Drinks cartons are the exception the schemes write in by name. Verpact charges one carton rate, EUR 0.92 per kg in 2026, on every material in the carton including its cap and spout, and ARA, Fost Plus and Citeo all give cartons their own line; Ledger 50 prices those lines in detail.

The EU layer: what the PPWR changes for composites

Regulation (EU) 2025/40 has applied since 12 August 2026 and brings the first EU-wide definition of composite packaging into a regulation (EUR-Lex record). It does not set fees, but it decides which EU rules a composite pack meets, and from 2030 its recyclability grades are due to modulate fees. Exhibit 10 sets out the provisions that touch composites.

The Commission’s notice is plain about the threshold and its reach. It says the definition introduces a 5% threshold below which packaging is a monomaterial, and that composite packaging, including paper-based packaging with 5% or more plastic, is covered by the packaging bans in Article 25 and Annex V (Notice C/2026/3084, section 16). The notice adds that the plastic parts exemption in Article 7(5)(b) should be read in line with the composite definition (section 7). For the design-for-recycling grades and their dates, see the tracker record PR-EU-010.