The home and personal care formats that US fees price hardest are the ones Colgate-Palmolive, Henkel, Reckitt and Kimberly-Clark report least

Four portfolios, four ways of counting

The four companies measure packaging in ways that cannot be lined up. Colgate-Palmolive counts PCR plastic and a recyclable, reusable or compostable share of all packaging. Henkel counts recycled plastic in consumer goods packaging and a designed-for-recycling share. Reckitt counts plastic packaging only. Kimberly-Clark counts a net plastics footprint that subtracts plastic waste collected for beneficial use. Exhibit 2 sets them out in their own units.

Only one of the four publishes packaging tonnage in a form SPI could read. Reckitt’s ESG Data Book 2025 lists 176,551 tonnes of plastic packaging, reported a year in arrears, and 264,293 tonnes of paper and board for 2024, which predate the sale of its Essential Home business on 31 December 2025. SPI has not yet confirmed the year of the glass and metal rows in that table, so no total is derived. Colgate-Palmolive, Henkel and Kimberly-Clark state no packaging tonnage in the reports SPI read.

The food giants’ pledges piece compared five food companies on virgin plastic baselines. HPC differs in two ways that matter here. Its packs carry more components per unit, such as pumps, triggers, caps and valves, and a large part of the portfolio is personal care product that some US laws treat as cosmetics or drugs, not as household goods.

The 2025 scorecard, company by company

All four companies had 2025 packaging goals. Exhibit 3 shows each one against the company’s own reported outcome, without a combined count, because the targets measure different things.

The 2030 goals that replace them are narrower. Colgate-Palmolive keeps a 33% virgin plastic cut against 2019 and sets all packaging designed for recycling. Henkel set at least 35% recycled materials and 100% designed for recycling on 14 April 2026. Reckitt keeps a 50% virgin plastic cut against 2020 and says its 2025 results will inform the refreshed 2030 packaging goals it sets (Sustainability Report 2025, p. 11). Kimberly-Clark keeps its 50% plastics footprint cut against 2019. None of the four has a 2030 reuse or refill target in the sources SPI read.

What the PPWR asks of HPC formats, and when

The PPWR does not name detergents, shampoos or tissue. It reaches them through general duties that apply to every pack, timed by acts the Commission has still to adopt (Exhibit 4). The EU tracker page holds the rule records (PR-EU-001, PR-EU-003, PR-EU-004, PR-EU-006, PR-EU-008, PR-EU-009, PR-EU-010).

Exhibit 5 sets the duties against the five formats this piece covers.

Refill and reuse

The Regulation treats refill as prevention, not as a reuse target. Recital 89 introduces refill as a new concept and a specific waste prevention measure, and recital 90 asks operators who offer refill to protect health and safety and to tell end users how to refill safely. The EUR-Lex summary adds that from 2030 large retailers must endeavour to dedicate 10% of sales area to refill stations, and that operators offering refill must tell consumers which containers they can use and which hygiene rules apply.

The binding reuse targets of Article 29 apply to transport packaging (40% from 2030) and grouped packaging (10%), not to HPC sales packs (PR-EU-006). The Commission Notice adds that Member States may, under Article 51(2)(c), require manufacturers or final distributors to offer products in reusable packaging outside the Article 29 targets, provided the internal market is not distorted. SPI analysis: an HPC refill format faces no EU quota in 2030, but national refill obligations under Article 51 can come sooner, and a pouch sold as a refill is still single-use packaging that must meet every recyclability and recycled-content test.

Trigger sprays and pumps

The PPWR counts a component as part of the pack. The Commission Notice reads Article 3(1)(b) to cover components and ancillary elements integrated into a packaging item (section 1). For recycled content, Article 7(5)(b) exempts any plastic part under 5% of the unit’s total weight, and the manufacturer must document each plastic part of 5% or more (section 7). A trigger head on a light spray bottle may cross that line where a cap on a heavy jug does not. Recyclability is assessed for the whole unit, so a head that cannot be separated or sorted pulls the unit’s grade down once the Article 6(4) criteria apply.

Flexible pouches

Pouches meet the recyclability grades. Recital 28 sets grades A, B and C, packaging below grade C is treated as technically non-recyclable, and the floor rises to grade B from 1 January 2038 (PR-EU-010). The delegated acts with the design criteria are due by 1 January 2028 (Green Forum). Henkel is a founding member of CEFLEX, a consortium of more than 130 European companies working to make flexible packaging easier to recycle (Henkel sustainable packaging page).

Tissue and hygiene wrap

The tissue roll, nappy or wipe is the product, and the film around it is the pack. The Single-Use Plastics Directive (Directive (EU) 2019/904) already lists sanitary towels, tampons and applicators, and wet wipes in Part D of its Annex, so each must carry a marking on its packaging or on the product itself from 3 July 2021. Wet wipes are also in Part E, Section II, which brings their producers into EPR schemes under Article 8(3) by 31 December 2024. Film that groups several packs is grouped packaging under the PPWR. SPI has not yet confirmed from the restricted-use column of Annex V whether multipack film on tissue rolls falls within entry 1.

Aerosol cans

Aerosols carry two sets of rules. Their safety is set by the Aerosol Dispensers Directive 75/324/EEC, last amended by Commission Directive (EU) 2016/2037 of 21 November 2016, which changed the pressure limits to allow more non-flammable propellants. As packaging, a steel or aluminium can falls under the general recyclability and labelling duties, while the Article 7 floors apply only to plastic parts, such as a cap or valve housing of 5% or more of the unit’s weight.

US EPR: seven state laws, two fee schedules in force

Seven US states in the SPI Regulation Tracker have packaging EPR laws (Exhibit 6), all tracked on the US tracker page. Oregon and Colorado are charging. California’s programme plan is under review. Minnesota, Maryland and Washington are in registration and membership stages, and Maine has no stewardship organisation yet.

California is the largest decision of the next quarter. CalRecycle’s targets are 10% less single-use plastic from 2027, 30% recycled from 2028, 20% less and 40% recycled from 2030, and 25% less, 65% recycled and 100% recyclable or compostable packaging from 2032 (CalRecycle Producer Guidance). The Covered Material Categories List is next due to be updated by 1 January 2027.

New Jersey’s law cuts through the HPC portfolio along product lines. Its FAQ of 12 May 2025 defines a rigid plastic container as 8 fluid ounces to 5 gallons, sets 10% PCR from 2024, 20% from 2027, 30% from 2030, 40% from 2033 and 50% from 2036, and exempts cosmetics, drugs, medical devices and dietary supplements as defined in the federal Food, Drug, and Cosmetic Act, and containers of FIFRA-registered pesticides. Other toxic or hazardous products are not exempt. A Henkel detergent jug is covered; a shampoo bottle that meets the cosmetic definition is not. Henkel’s North American liquid laundry brands already use at least 50% recycled plastic in bottle bodies, the level New Jersey reaches only in 2036.

What each format costs in Oregon and Colorado

CAA’s 2026 schedules price every HPC format SPI looked at, in US cents per pound (Exhibit 7). Rates are converted to US dollars per metric tonne at 22.0462, and each state is read on its own.

Three patterns stand out. First, colour costs more in Oregon than in Colorado: pigmented HDPE is 3.6 times natural in Oregon and 1.6 times in Colorado. Second, the two states disagree most on aerosols, which Oregon prices at 6.4 times a steel can and Colorado at 2.0 times. Third, the step from mono PE to laminate is 2.4 times in Oregon and 1.5 times in Colorado, so the same pouch redesign is worth more in one state than in the other.

Colorado also runs active incentives for recycled content, reuse or refill, reduction and enhancement, claimed through the producer portal on top of the passive factors (CAA 2026 Colorado schedule, as summarised in SPI’s fee notes). Oregon offers a life cycle evaluation bonus, whose 2026 value is not printed in the schedule (SPI fee notes).

When does a refill pouch pay?

Fees are charged by weight, so a refill pouch saves money only when it is light enough to offset its higher rate. Exhibit 8 gives the break-even: the largest share of the replaced bottle’s weight that the pouch can have and still lower the fee.

A framework: four HPC format archetypes

SPI sorts HPC formats into four archetypes, set by two tests drawn from the data above: the multiple a format pays over the cheapest container line of its material in the CAA schedules, and whether EU law has a duty aimed at that format rather than at all packaging (Exhibit 9). The archetypes are an SPI device for portfolio review, not a legal category.

The grid shows where reporting and cost diverge. Archetype 4 is where the companies report most, because it is where the portfolio-wide metrics are earned: Colgate-Palmolive’s recyclable tube covers about 98% of its toothpaste SKUs and is available in more than 70 countries, and Henkel’s European detergent bottles up to 3 litres carry 65% PCR. Archetype 1 is where a tonne costs most, and it is reported least.

Scenarios: one HPC basket priced in Oregon and Colorado

SPI priced a 100-tonne HPC packaging basket through both 2026 CAA schedules (Exhibits 10 and 11). The basket is an SPI assumption, not any company’s mix: 20 tonnes of natural HDPE bottles, 20 of pigmented HDPE, 10 of PP bottles, 10 of clear PET spray bottles, 5 of pump and trigger heads priced as mixed rigid plastic, 15 of PE film, 5 of laminate pouches, 5 each of steel and aluminium aerosol cans, and 5 of paperboard. All figures are in US dollars, and each state is shown on its own.

The working for the Oregon base is 20 x 198.42 + 20 x 705.48 + 10 x 837.76 + 10 x 551.15 + 5 x 2,138.48 + 15 x 947.99 + 5 x 2,248.71 + 10 x 1,410.96 + 5 x 176.37. Converting the unrounded total of 3,770 tonne-cents per pound once at 22.0462 gives USD 83,114.17; adding the rounded line values above gives USD 83,114.35. Aerosols are 10% of the weight and 17.0% of the Oregon bill, against 5.1% in Colorado, where both aerosol lines sit on the minimum recyclable list.

In practice: four companies

Kimberly-Clark, Suzano and Arbex: who reports what

Kimberly-Clark’s international tissue business is no longer its own. Kimberly-Clark announced the joint venture on 5 June 2025, and its 10-Q for the quarter to 30 June 2026 says the IFP transaction was completed on 1 July 2026, with the buyer taking 51% and Kimberly-Clark retaining a 49% equity interest. Suzano’s material fact of the same day says it acquired 51% of FamPro Tissue Holdings B.V., to be called Arbex, and its 2Q26 release of 12 August 2026 says Suzano obtained exclusive control. Exhibit 12 sets out which entity reports what.

Arbex’s headquarters are in the Netherlands, with an operational office in London (Arbex release, 1 July 2026). Kimberly-Clark’s portfolio is also set to widen: it agreed to acquire Kenvue on 2 November 2025, and the joint release of 29 January 2026 says the transaction is expected to close in the second half of 2026, subject to regulatory approvals. SPI has not yet confirmed the closing.

The pace each company needs to 2030

Exhibit 13 gives the straight-line pace from each company’s latest figure to its own 2030 target. Each row is in its own unit and is not compared with any other.

SPI calculation: Kimberly-Clark’s 16 points over six years since 2019 average about 2.7 points a year, so the 2030 goal needs about 2.5 times its past pace. Reckitt gained 3 points from 2023 to 2024 against 5.3 needed. Colgate-Palmolive is 1 point from its 2030 virgin plastic goal, which it had already set for 2025.