# How are EPR fees calculated? Schemes set rates in 12 of 14 markets, and regulators mostly approve the method

> EPR fees are calculated by taking the net cost of collecting, sorting and recycling each packaging material, after material sales revenue, adding administration and other required costs, and dividing by the tonnes producers report; in 12 of the 14 fee markets Strategic Packaging Insights (SPI) tracks, the producer scheme sets the schedule, and only the UK and the Isle of Man have a public body fix the charge itself.

Publisher: Strategic Packaging Insights  
Published: 2026-11-03  
Last updated: 2026-11-03  
Page: https://www.strategicpackaginginsights.com/insights/how-epr-fees-are-calculated-governance-14-markets/

**EPR fees are calculated by taking the net cost of collecting, sorting and recycling each packaging material, after material sales revenue, adding administration and other required costs, and dividing by the tonnes producers report; in 12 of the 14 fee markets Strategic Packaging Insights (SPI) tracks, the producer scheme sets the schedule, and only the UK and the Isle of Man have a public body fix the charge itself.**

SPI read the fee-setting rules in the governing laws, licences and scheme documents of all 14 markets in its EPR & Plastic Tax Calculator. The formula is broadly shared; what differs is who signs the schedule off, what the law says it may cover and how much notice producers get, from 29 days on the Isle of Man to 129 days for CONAI's October 2026 plastic change.

## Executive summary

Most published guides to extended producer responsibility fees list rates. This piece looks one step earlier, at the machinery that produces them: the formula, the people who sign it off and the calendar they work to. It covers all 14 markets in the SPI EPR & Plastic Tax Calculator: Austria, Belgium, British Columbia, Colorado, France, Ireland, the Isle of Man, Italy, Luxembourg, the Netherlands, Oregon, Portugal, Spain and the United Kingdom. Rates themselves are in [SPI's per-tonne comparison](https://www.strategicpackaginginsights.com/insights/epr-fees-per-tonne-2026/) and are not repeated here.

The formula is close to universal. A scheme budgets the net cost of each material stream, meaning collection, sorting and recycling less the money it gets for the bales, adds its administration and any reserve, and divides by the tonnes its members report. Fost Plus calls this the real cost deficit per material; PackUK divides net council cost by household tonnage; Circular Action Alliance (CAA) credits commodity revenue to the materials that earned it; Austria's packaging ordinance requires a traceable cost calculation spread over the mass in each tariff category (Exhibit 4).

Governance is where markets split. SPI groups them into four models (Exhibit 5). In two, the state sets the charge. In three North American markets, the regulator approves a programme plan that fixes the method and the scheme sets each year's rates within it. In four European markets, the scheme sets rates but a public body sees them first: Belgium's Interregional Packaging Commission, Austria's environment ministry with an auditor's opinion, France's stakeholder committee and ministry, and Ireland's Minister. In the other five, the scheme's own board or general assembly has the last word, inside the limits of its licence.

Timing is the practical risk. Producers had 64 days' notice of Oregon's 2026 schedule and 129 days of CONAI's October 2026 plastic change, while UK producers learn their year 2 bill in November 2026, eight months into the year it covers (Exhibit 8). Several schemes also reserve the right to change fees mid-year.

For leaders, the message is to manage fee governance like a supplier contract: know who decides, when, on what data, and where your trade body can be heard before the number is final.

## Key findings

1. In 12 of 14 markets the producer scheme sets the annual fee schedule; only PackUK in the UK and the Isle of Man Treasury, which by statute follows the UK plastic packaging tax rate, fix the charge as public bodies (SPI analysis, Exhibit 2).
2. All six schemes whose method SPI could read in full (Exhibit 4) price fees from a net cost per material divided by reported tonnage; Colorado's law adds two hard limits, 100% of service providers' net recycling services costs reimbursed and no more than 5% of dues spent on administration (C.R.S. 25-17-705(4)(i) and (j)).
3. Four European schemes face an ex ante public check: Fost Plus sends rates and method to the Interregional Packaging Commission after its June board, ARA must notify planned tariff changes to the ministry with an auditor's opinion, Citeo needs a published stakeholder committee opinion, and Repak's fee structure must satisfy Ireland's Minister.
4. France is the one market where the state also writes part of the modulation itself: an arrêté of 5 September 2025, issued after a commission opinion of 13 March 2025 and a public consultation, fixes recycled-plastic primes for packaging from 1 January 2026.
5. **SPI calculation:**  in the 2026 cycle, notice ran from 29 days (Isle of Man) and 64 days (CAA Oregon) to 101 days (Verpact) and 129 days (CONAI plastic); for 2027, CAA published on 1 October 2026, 92 days ahead, and Recycle BC on 21 October, 72 days ahead.
6. **SPI calculation:**  under the UK's cost-neutral modulation, the green discount needed to offset a red factor of 1.2 is 5.9% at a 21% red share of rated tonnage, rising to 29.6% at a factor of 2.0, against PackUK's provisional figure of about 9% for year 2 (Exhibit 10).

## Who sets and who approves the schedule in 14 markets

Exhibit 2 is the core of this piece: for each market, the body that sets the schedule, the body that approves or checks it, the costs the fee must cover and when the schedule is published. It is built from each market's law or licence and the scheme's own fee documents, read between 14 October and 3 November 2026.

Three things stand out. First, the word "approval" means different things. In Oregon, Colorado and British Columbia the regulator approves a plan, and the plan, not each schedule, carries the method. In Ireland the approval sets conditions on the fee structure itself. In Luxembourg the ministerial approval sets the floor and the criteria, while Valorlux's general assembly approves the numbers.

Second, competition changes the picture. ARA in Austria held a 72.2% share of licensed volume in 2024 against other licensed systems (ARA general assembly, 18 June 2025). Where producers can switch, price discipline comes partly from the market and the regulator's role is to police tariff principles, not to set rates.

Third, the gaps are real. SPI could not find a published rule naming who approves the yearly tables in Spain, Portugal or the Netherlands. SPI has not yet confirmed whether Spanish, Portuguese or Dutch authorities sign off each year's numbers, and readers should ask their scheme directly.

## What the law says EPR fees must cover

Fee methods differ, but the legal tests behind them are close. In the EU the anchor is Article 8a(4) of the Waste Framework Directive, which says producer contributions must cover separate collection, transport and treatment, information to waste holders and data reporting, net of revenue from reuse, material sales and unclaimed deposits; must be modulated where possible in collective schemes; and must not exceed the costs of a cost-efficient service (Directive 2008/98/EC, consolidated 5 July 2018). Regulation (EU) 2025/40 has applied since 12 August 2026, and the national rules below still carry these tests.

The words "net necessary cost" do a great deal of work. In Ireland, the approval's success factors list "Net Necessary Cost %" as a measured indicator, and Repak is working with the Department on a consultant's review of the net necessary cost system (Repak approval; Repak annual report 2025). In Spain, the decree's preamble says contributions must be set transparently between the actors concerned, taking into account costs incurred by public and private waste managers, and that collective systems must return excess income each year (RD 1055/2022, preamble IV).

SPI analysis

The cost floor is set by law almost everywhere, but the ceiling is usually a principle rather than a number. Colorado's 5% administration cap is the only hard numeric ceiling SPI found in the 14 markets. Elsewhere, the ceiling depends on who audits "cost-efficient", which is a governance question, not a formula.

## How are EPR fees calculated? From net cost to a rate per kilogram

Every EPR scheme whose method SPI could read in full follows four moves: build a cost budget, assign it to materials, net off material revenue, and divide by reported tonnage. The order and the extras differ (Exhibit 4).

The shared logic has a consequence producers often miss: rates move when tonnage moves, even if costs do not. Oregon DEQ stresses that because rates follow reported supply, they change every year and late or missing data distorts them (Oregon DEQ, producers of covered products). PackUK's year 2 calculation left the costs of littered and on-the-go packaging out of the numerator while keeping their tonnage in the denominator (GOV.UK, updated 19 December 2025), which lowers the rate per tonne for everyone.

In practice: Fost Plus.

Fost Plus publishes its method in plain terms. Rates are calculated on the real cost deficit for each recycled material; the board approves budget and rates in June; they go to the Interregional Packaging Commission with the calculation method; and the general meeting confirms them (Fost Plus, what, why and how). Non-recyclable packaging is priced at least double the highest recyclable rate, and the extra money is shared across recyclable materials by recycling percentage. Surpluses and shortfalls for a material flow into its rate the following year, so a member's bill in year two partly settles year one.

In practice: CAA in Oregon.

CAA's first-year explainer of 29 May 2025 starts from total system cost and adds reserves, regulatory costs and PRO administration, then credits commodity revenue to the categories that earned it and divides by reported supply to reach a base rate per pound (CAA-401). The 2026 schedule prints a base fee, a system investment portion and a final rate for every line; the investment portion was zero on every row, so the final rate equalled the base (CAA 2026 Oregon schedule). Oregon's statute requires fees for each product type to be proportional to the costs they cause the PRO and lets CAA propose an alternative structure only with DEQ approval (ORS 459A.884(1) and (5)). For the line-by-line rates, see [SPI's Oregon and Colorado schedule piece](https://www.strategicpackaginginsights.com/insights/oregon-colorado-epr-fee-schedules-line-by-line/).

## Extended producer responsibility fees, market by market: the yearly cycle in eight markets

Exhibit 4 shows the method where schemes publish it in full. The yearly cycle matters as much, because it is what a producer has to plan around. Here it is for eight markets, including two from Exhibit 4 where the cycle adds something.

**Spain.**  Ecoembes publishes one price per kilogram for each material and format, with separate lines for packaging inside the Single-Use Plastics Directive scope, and then moves the base price up or down per packaging element through its eco-modulation guide (Ecoembes Precios 2026; Guía de ecomodulación 2026). The guide is calibrated on final annual declaration data for year n-2, and the euros raised by penalised tonnes are the ceiling for bonuses in the same fraction, so the modulation is self-funding by design. The legal frame is RD 1055/2022, whose preamble lists the modulation criteria and provides for an analysis of their effects within four years.

**Portugal.**  Sociedade Ponto Verde (SPV) sets a value per kilogram by material, by urban or non-urban flow and, for single-use plastic cups, by unit, with a reduced value 10% below the base for packaging that meets every eco-modulation criterion for its material (SPV Tabela VPV 2026). The UNILEX law requires each producer's contract with the managing entity to state the financial contributions owed and how they are updated (UNILEX, article 10(3), per the APA manual). SPV's 2026 table first appeared in December 2025 and was reissued in June 2026 with the same values. SPV also reports a fall of about 26% in the resale prices of recovered materials in 2025, which raises the net cost the fees must cover (SPV activity report 2025).

**Luxembourg.**  Valorlux publishes its tariff each autumn for the following year after its general assembly; the 2026 detailed table is marked GV October 2025 (Valorlux 2026 table). Its board also sets a minimum contribution, which the general conditions cap at EUR 125, and members pay quarterly advances adjusted later by a complementary invoice or credit note (Valorlux general conditions, articles 5.3 and 5.4).

**Netherlands.**  Verpact sets one tariff per material each year from the expected costs of meeting its legal duties, and folds in surpluses or deficits from earlier years (Verpact Tarieven). The fee is owed by every obliged firm, signatory or not, because the state has declared the 2023 to 2027 waste management contribution agreement generally binding (Ondernemersplein). Modulation is a discount on the plastic tariff adopted under the agreement's annex, not a set of bands, and it is redesigned for 2027 (Verpact Tariefdifferentiatie 2027).

**Italy.**  CONAI's Board of Directors sets each value after monitoring the finances of the material consortia and announces changes months ahead with a stated effective date (CONAI, 25 May 2026). The fee is charged at the first transfer of finished packaging inside Italy, on the seller's invoice, rather than when goods reach the shelf, so the fee cycle runs through the supply chain's own invoicing (CONAI 2026 value table).

**Colorado.**  CAA's 2026 dues schedule, published on 13 October 2025, lists base dues per material and then applies eco-modulation automatically, as the Act requires (CAA 2026 Colorado schedule). The Act also requires an annual report with the schedule of dues by weight for each material, the total collected and the reasons for changes, which the advisory board reviews and the department posts (C.R.S. 25-17-709(2)(a)). The executive director had to produce a bonus schedule by 1 January 2026 and must revisit it each year.

**British Columbia.**  Recycle BC's plan, approved on 17 September 2025, sets the allocation rules: every obligated material bears a fair share of cost even when it is not collected, commodity revenue goes only to the materials that earn it, and extra cost is loaded onto uncollectable or underperforming categories to fund improvement (Recycle BC plan). Beverage container revenue is netted off gross programme cost before material fees are worked out. Recycle BC's 2027 schedule came with cause-of-change graphs that split each line's movement into the factors in its model, as SPI's [report on the 2027 schedule](https://www.strategicpackaginginsights.com/news/recycle-bc-2027-fee-schedule/) and [Canada EPR overview](https://www.strategicpackaginginsights.com/insights/canada-packaging-epr-by-province/) set out.

**Isle of Man.**  The Island runs no calculation. Its Treasury notice of 3 March 2026 says the rate must stay aligned with the UK figure, which Westminster sets in section 45 of the Finance Act 2021, and the Manx change took effect on 1 April 2026, the same day as the UK one (Isle of Man Government, 3 March 2026). Recycled content decides the bill: components below 30% recycled plastic pay, those at or above it do not.

SPI analysis

The eight markets fall into three groups. Spain, Portugal and Colorado publish modulation rules in detail, while their base-rate arithmetic sits in legal tests or plans rather than a worked public method. Italy and Luxembourg publish least and rely on board or assembly decisions inside the licence. British Columbia and the Netherlands publish both the method and the cause of each change. For a buyer, both groups make the scheme's annual report and assembly papers the best public source of the cost budget behind the rate.

## A framework: four ways to govern a fee schedule

Exhibit 5 sets out SPI's framework. It sorts markets by one question: who has the last word on the yearly number, and what check, if any, sits before it.

Model A gives the most predictable method and the least room to bargain. PackUK publishes its modulation rules in a statement, and the red factor rises on a set path: 1.2 in year 2, 1.6 in year 3 and 2.0 in year 4 (PackUK modulation statement). The Isle of Man has no method of its own at all; its Treasury says the rate must stay aligned with the UK rate under the 1979 Customs and Excise Agreement (Isle of Man Government, 3 March 2026).

Model B front-loads the argument. In Colorado, the PRO must seek and consider advisory board input when it drafts the plan; the board reviews the plan and any proposed amendment and forwards a recommendation; and the executive director approves or rejects within 120 days, on the plan requirements alone (C.R.S. 25-17-705(4), (5) and (6)). The plan must provide for annual updates to the dues schedule. The statute does not say whether each annual update counts as an amendment needing approval, and SPI has not yet confirmed CDPHE's reading. British Columbia's ministry approved Recycle BC's plan on 17 September 2025 and will next review it by 15 April 2028 (Recycle BC plan and approval).

Model C adds a checkpoint without handing the pen to the state. Austria's ordinance requires each system to publish general tariffs per category, treat partners equally, allow no rebates and notify planned tariff changes to the minister in good time, attaching the calculation basis and an auditor's opinion on the tariff principles (VerpackVO § 9(2) and (3), unofficial consolidation). France goes furthest: a stakeholder committee of producers, waste operators, local authorities and associations must publish an opinion before Citeo decides on the contribution amount, support scales and eco-modulation proposals, and Citeo may not act before the opinion is out unless it shows urgency (Citeo, governance fact sheet, 18 February 2025).

Model D relies on the licence and on membership. Italian law has CONAI determine the fee in proportion to the quantity, weight and type of packaging, under a statute the environment minister approves by decree (D.Lgs. 152/2006, art. 224(1) and (3)(h), unofficial text). Valorlux's ministerial approval requires contributions to cover at least the costs the law places on producers and to be modulated by seven criteria, but Article 4 contains no step for ministerial approval of the rates (Valorlux approval, Art. 4).

SPI analysis

The model predicts the type of surprise. Model A surprises on timing, because the bill arrives late. Model B surprises on data, because rates move with reported supply. Model C surprises least, because a third party sees the numbers first. Model D can surprise on mid-year changes, because the decision sits inside the scheme.

## Where producers get a say before fees are final

The governance model decides where influence works. Exhibit 6 lists the formal routes SPI found in published documents.

The French vote shows how the route works in practice. On 8 June 2026, Citeo's stakeholder committee approved the eco-modulation proposals for 2027 with 6 votes in favour, none against and 5 abstentions (Citeo CPP opinion, 8 June 2026). SPI has not yet confirmed Citeo's 2027 tariff against Citeo's own guide.

France also shows the state stepping into modulation directly. The arrêté of 5 September 2025 sets primes for recycled plastic across several EPR streams, including household packaging. Its recitals cite the opinion of the inter-sector EPR commission of 13 March 2025, a public consultation from 11 March to 1 April 2025 and notification to the European Commission on 4 September 2025, and it applies from 1 January 2026 (arrêté of 5 September 2025, via AIDA). Citeo's 2026 guide says that prime can be combined only with the reduction, grouping and small-format maluses (Citeo guide 2026).

Ontario, outside the 14 markets, is moving the other way, from scheme discretion toward rules. ERO notice 026-1058, posted on 27 October 2026 with comments to 26 November, would require PROs to publish proposed and final fee schedules and itemise system costs on invoices (ERO 026-1058). SPI's [report on the notice](https://www.strategicpackaginginsights.com/news/ontario-blue-box-flexible-plastic-pro-fee-transparency-november-26/) covers the detail.

## Which data the fee rests on, and how it is trued up

A fee is a rate times a tonnage, and the tonnage period is a governance choice too. Exhibit 7 shows which data each scheme bills on and how errors are corrected.

In practice: Repak.

Repak's approval for 1 January 2026 to 30 September 2035, with reviews planned in the first halves of 2029 and 2032, makes the fee-setting process a regulated one: fees follow the polluter-pays principle, must not exceed the cost of a cost-efficient service, and the structure must be shown to the Minister's satisfaction to meet the Waste Framework Directive (Repak approval, sections 9 and 22). Repak also spreads the fee along the chain: the material maker, converter and retailer pay fixed shares and the brand holder carries the variable share. Invoices go out in January and July on the same half of the previous year, so a tonnage cut in 2026 shows in 2027 invoices (Repak QF 509).

The PackUK case is the opposite. Its operational plan says the year 2 notice of liability will be issued by the end of November 2026, after the fees are calculated that month, on data frozen on 1 September 2026, with no plan for a producer-wide recalculation (PackUK operational plan, updated 10 August 2026). SPI's [report on the November notices](https://www.strategicpackaginginsights.com/news/packuk-year-2-notices-of-liability-november/) sets out the payment terms.

## When EPR fees are published: lead times from 29 to 129 days

The date a schedule appears is the producer's real budget deadline. Exhibit 8 counts the days from the public release SPI could date to the day the fee first applied.

Two schemes publish much earlier than the rest. Ecoembes put its 2027 prices online in August 2026, and Verpact published a 2027 forecast in July 2026, presented at a webinar on 7 July, before setting final tariffs that it says largely match it (Verpact Tarieven page). Citeo's calendar is fixed: tariff and eco-modulation are announced in September of the year before the packaging is placed on the market (Citeo guide 2026). For the euro schemes' 2025 to 2026 moves, see [SPI's Benelux fees piece](https://www.strategicpackaginginsights.com/insights/benelux-packaging-fees-fost-plus-valorlux/).

SPI analysis

The North American schemes publish latest, because their rates depend on supply data reported in the same year: CAA's 2027 Oregon fees rest on 2025 supply data due by 31 May 2026. The UK publishes last of all, after the year has started. A producer that budgets in September for the following calendar year will have final numbers for ARA, Verpact, Fost Plus, Ecoembes and Citeo, but not for CAA in a year when it publishes in late October, and not for PackUK.

## Mid-year changes and exit rights

An annual schedule is not always annual. Exhibit 9 lists the published rules on changing fees inside a year.

CONAI's October 2026 change is the clearest recent case. Its Board of Directors set new plastic values after talks with the supply chain and the plastics consortium COREPLA, effective 1 October 2026, citing volatile markets, rising management costs, weak demand for some recycled fractions, mainly in bands B2 and C, and the aim of keeping recycling at 50% or more (CONAI, 25 May 2026). The start date, CONAI said, balanced the system's finances against giving companies enough notice.

## Scenarios: how modulation shares out a fixed UK bill

Modulation changes who pays, not how much the system costs, in schemes that are cost-neutral by design. PackUK's statement says modulation will affect how costs are allocated by material and will not raise total disposal fees (PackUK modulation statement). Fost Plus shares non-recyclable revenue across recyclable materials, and Ecoembes caps bonuses at the money raised by maluses in the same fraction (Ecoembes guide 2026). Exhibit 10 shows what that means for the UK green discount.

The table carries a governance point. In a cost-neutral design, a green-rated producer's bill depends on how much red packaging other producers report, which no single firm controls. The rising factor raises the stakes: at the base case, the discount needed triples from year 2 to year 3. PackUK says the factors will be reviewed no later than 2028, and its RAM change process runs to 31 December 2026 (PackUK modulation statement; GOV.UK, 22 October 2026). The tracker record [PR-GB-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-002/) holds the regulation.

## Industry reaction

> "Such costs shall be established in a transparent way between the actors concerned."

***European Union** , [Waste Framework Directive, Article 8a(4)(c)](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:02008L0098-20180705), consolidated text of 5 July 2018*

The sentence sets a process test, not a number. Ireland's approval turns it into a named process with producers and the Department; most other markets leave it to the scheme's own bodies.

> "Any surpluses and shortfalls are incorporated into the rates for the following year."
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> **Fost Plus** , Belgian household packaging scheme, [Packaging EPR rates: what, why and how](https://www.fostplus.be/en/media/2252/download), consulted 3 November 2026
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> "We stellen de tarieven jaarlijks vast op basis van de verwachte kosten voor het komende kalenderjaar."
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> **Verpact** , Dutch packaging producer organisation, [Tarieven](https://www.verpact.nl/nl/tarieven), consulted 3 November 2026
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> "Only once the household packaging waste disposal fee has been calculated can the modulated fees be calculated."

In English: "We set the tariffs each year on the basis of the expected costs for the coming calendar year."

***PackUK** , UK scheme administrator, [Producer disposal fees modulation statement](https://www.gov.uk/government/publications/extended-producer-responsibility-for-packaging-modulated-disposal-fees/packuk-extended-producer-responsibility-epr-for-packaging-producer-disposal-fees-modulation-statement), GOV.UK, updated 17 February 2026*

Read together, the scheme statements describe the same cycle: budget forward, settle backward, then modulate. The difference lies in who checks each step.

## What leaders should do now

1. **Head of EPR compliance, by 31 December 2026:**  map each market you sell into against Exhibit 2, record who sets and who approves the schedule, and name the date the next one is published.
2. **Finance director, in the 2027 budget round:**  set budget deadlines by market, using the publication dates in Exhibit 8, and hold a contingency for PackUK and for any CAA schedule that arrives after your budget closes.
3. **Data owner, before each tonnage deadline (31 May for Recycle BC, 28 February for Fost Plus, 21 February and 21 August for Repak):**  check reported tonnage against sales, because rates in most schemes divide cost by the same tonnage.
4. **Government affairs, by 26 November 2026 for Ontario and 31 December 2026 for UK RAM 2028:**  use the formal routes in Exhibit 6, through your trade association where seats are held there.
5. **Procurement and legal, in the next contract review:**  read your scheme's terms for mid-year change and exit rights, such as ARA's three-week termination window, and check with counsel what notice your own contracts need.
6. **Packaging design leads, from January 2027:**  in cost-neutral schemes, treat a green rating as a discount that depends on other producers' red tonnage, and model it as a range (Exhibit 10).

## Questions for your board

- In which of our markets does a public body see the fee schedule before it applies, and in which does the scheme decide alone?
- How much of our EPR spend is set on tonnage we report, and who signs that data off?
- Which of our schemes can change fees inside a year, and what notice would we get?
- Are we represented, directly or through a trade body, on the committees and assemblies that approve fees?
- What would a late UK notice of liability or CAA schedule do to our quarterly cash forecast?
- If red packaging falls across the market, how much of our green discount would disappear?

## What to watch

- **26 November 2026:**  comments close on Ontario ERO notice 026-1058 on PRO fee publication and itemised invoices.
- **By 30 November 2026:**  PackUK issues year 2 notices of liability after calculating fees in November.
- **11 December 2026:**  comments close on ARMA's draft 2027 oversight fee in Alberta, outside the 14 markets.
- **31 December 2026:**  evidence deadline for producer change requests to the UK RAM for 2028.
- **1 January 2027:**  2027 tables apply at ARA, Fost Plus, Verpact, Valorlux, Ecoembes, CAA Oregon and Colorado, and Recycle BC.
- **First half of 2029:**  first planned review of Repak's approval.

## Methodology

- **Data used:**  the fee_setting and scheme_explainer sections of SPI's 14 fee-market files (Austria, Belgium, British Columbia, Colorado, France, Ireland, Isle of Man, Italy, Luxembourg, Netherlands, Oregon, Portugal, Spain, United Kingdom), as of 14 October 2026, brought up to date from the primary sources listed below between 14 October and 3 November 2026.
- **Classification:**  each market is placed in one governance model (Exhibits 1 and 5) by where the yearly decision sits and what check, if any, comes before it. This is SPI's reading, not a legal classification. A plan approval counts as a check on the method, not on the yearly number.
- **Legal texts:**  the Austrian ordinance is read in an unofficial consolidation (gesetzefinden.at), Italian art. 224 on Brocardi.it and ORS 459A.884 on Oregon.public.law; SPI has not yet confirmed these points against the official gazettes. Spanish RD 1055/2022 is read from its preamble; SPI has not yet confirmed the operative articles on publishing or reporting contributions.
- **Calculations:**  lead times are calendar days from the earliest public date SPI could find to the first day of application. The UK scenario uses percentages only and the assumptions in the Exhibit 10 note. No figures are converted or compared across currencies, and no rates are restated: for rates, see [SPI's per-tonne comparison](https://www.strategicpackaginginsights.com/insights/epr-fees-per-tonne-2026/) and [composite fee piece](https://www.strategicpackaginginsights.com/insights/composite-multi-material-packaging-epr-fees/).
- **Not yet confirmed:**  who approves each year's tables in Spain, Portugal and the Netherlands; whether Colorado's annual dues update needs CDPHE approval; whether Recycle BC's board formally adopts each schedule; Citeo's and Repak's 2027 rates; how PackUK treats tonnage without a RAM rating. Nothing here is legal advice.

## Sources

1. EUR-Lex: Directive 2008/98/EC, consolidated text of 5 July 2018, Article 8a, [https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:02008L0098-20180705](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:02008L0098-20180705), consulted 2026-11-03.
2. legislation.gov.uk: SI 2024/1332, regulation 60, [https://www.legislation.gov.uk/uksi/2024/1332/regulation/60/made](https://www.legislation.gov.uk/uksi/2024/1332/regulation/60/made), consulted 2026-10-14.
3. GOV.UK (PackUK): Producer disposal fees modulation statement, [https://www.gov.uk/government/publications/extended-producer-responsibility-for-packaging-modulated-disposal-fees/packuk-extended-producer-responsibility-epr-for-packaging-producer-disposal-fees-modulation-statement](https://www.gov.uk/government/publications/extended-producer-responsibility-for-packaging-modulated-disposal-fees/packuk-extended-producer-responsibility-epr-for-packaging-producer-disposal-fees-modulation-statement), consulted 2026-11-03.
4. GOV.UK (PackUK): Year 2 illustrative waste disposal fees (updated 19 December 2025), [https://www.gov.uk/government/publications/illustrative-waste-disposal-fees-2026-extended-producer-responsibility-for-packaging/year-2-illustrative-waste-disposal-fees-extended-producer-responsibility-for-packaging](https://www.gov.uk/government/publications/illustrative-waste-disposal-fees-2026-extended-producer-responsibility-for-packaging/year-2-illustrative-waste-disposal-fees-extended-producer-responsibility-for-packaging), consulted 2026-10-14.
5. GOV.UK: PackUK operational plan 2026 to 2027 (updated 10 August 2026), [https://www.gov.uk/government/publications/packuk-operational-plan/packuk-operational-plan-2026-to-2027](https://www.gov.uk/government/publications/packuk-operational-plan/packuk-operational-plan-2026-to-2027), consulted 2026-10-14.
6. Colorado General Assembly: HB22-1355, signed act, [https://content.leg.colorado.gov/sites/default/files/2022a_1355_signed.pdf](https://content.leg.colorado.gov/sites/default/files/2022a_1355_signed.pdf), consulted 2026-11-03.
7. ORS 459A.884, membership fee requirements (Oregon.public.law), [https://oregon.public.law/statutes/ors_459A.884](https://oregon.public.law/statutes/ors_459A.884), consulted 2026-11-03.
8. Circular Action Alliance: 2025 Oregon Producer Fee Schedule Explained (CAA-401, 29 May 2025), [https://wineinstitute.org/wp-content/uploads/2025/07/401_Oregon_Fee_Setting_Explained_1_May2025_1_.pdf](https://wineinstitute.org/wp-content/uploads/2025/07/401_Oregon_Fee_Setting_Explained_1_May2025_1_.pdf), consulted 2026-10-14.
9. Circular Action Alliance: 2026 Oregon Producer Fee Schedule (published 29 October 2025), [https://static1.squarespace.com/static/64260ed078c36925b1cf3385/t/693b2c9103be112d168e1b19/1765485713621/OR+2026+Fee+Schedule+Public.pdf](https://static1.squarespace.com/static/64260ed078c36925b1cf3385/t/693b2c9103be112d168e1b19/1765485713621/OR+2026+Fee+Schedule+Public.pdf), consulted 2026-10-14.
10. B.C. Government: Recycle BC plan (19 August 2025) and approval (17 September 2025), [https://www2.gov.bc.ca/assets/gov/environment/waste-management/recycling/recycle/residential-packaging-and-paper-recyclebc/recyclebc_plan_and_approval_2025.pdf](https://www2.gov.bc.ca/assets/gov/environment/waste-management/recycling/recycle/residential-packaging-and-paper-recyclebc/recyclebc_plan_and_approval_2025.pdf), consulted 2026-10-14.
11. Recycle BC: Fee schedule page, [https://recyclebc.ca/producers/reporting-fees/fee-schedule/](https://recyclebc.ca/producers/reporting-fees/fee-schedule/), consulted 2026-11-03.
12. 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 2026-11-03.
13. Repak: Approval as a packaging compliance scheme, 2026 to 2035, [https://repak.ie/images/uploads/downloads/Repak_Approval_2026_to_2035.pdf](https://repak.ie/images/uploads/downloads/Repak_Approval_2026_to_2035.pdf), consulted 2026-11-03.
14. Citeo: Fiche réflexe, instances de gouvernance (18 February 2025), [https://bo.citeo.com/sites/default/files/2025-08/250218_CITEO_FICHE%20REFLEXE_INSTANCES_DE_GOUVERNANCE.pdf](https://bo.citeo.com/sites/default/files/2025-08/250218_CITEO_FICHE%20REFLEXE_INSTANCES_DE_GOUVERNANCE.pdf), consulted 2026-11-03.
15. Citeo: Avis du Comité des Parties Prenantes (8 June 2026), [https://www.citeo.com/wp-content/uploads/2026/06/8-juin-2026-Avis-du-Comite-des-Parties-Prenantes-de-la-filiere-des-emballages-menagers-et-papiers-graphiques-de-Citeo.pdf](https://www.citeo.com/wp-content/uploads/2026/06/8-juin-2026-Avis-du-Comite-des-Parties-Prenantes-de-la-filiere-des-emballages-menagers-et-papiers-graphiques-de-Citeo.pdf), consulted 2026-11-03.
16. AIDA (INERIS): Arrêté du 5 septembre 2025 fixant les modulations applicables aux contributions financières, [https://aida.ineris.fr/reglementation/arrete-050925-fixant-modulations-applicables-contributions-financieres-versees](https://aida.ineris.fr/reglementation/arrete-050925-fixant-modulations-applicables-contributions-financieres-versees), consulted 2026-11-03.
17. Citeo: Guide du tarif des emballages ménagers 2026 (updated 22 June 2026), [https://clients-cms.citeo.com/uploads/guide_du_tarif_des_emballages_menagers_2026_f9e4c5b4e6.pdf](https://clients-cms.citeo.com/uploads/guide_du_tarif_des_emballages_menagers_2026_f9e4c5b4e6.pdf), consulted 2026-10-14.
18. Brocardi.it: D.Lgs. 152/2006, art. 224 (unofficial text), [https://brocardi.it/codice-dell-ambiente/parte-quarta/titolo-ii/art224.html](https://brocardi.it/codice-dell-ambiente/parte-quarta/titolo-ii/art224.html), consulted 2026-11-03.
19. CONAI: Imballaggi in plastica, definiti i nuovi valori del Contributo ambientale CONAI (25 May 2026), [https://www.conai.org/news-e-press/imballaggi-in-plastica-definiti-i-nuovi-valori-del-contributo-ambientale-conai/](https://www.conai.org/news-e-press/imballaggi-in-plastica-definiti-i-nuovi-valori-del-contributo-ambientale-conai/), consulted 2026-11-03.
20. Verpact: Tarieven, [https://www.verpact.nl/nl/tarieven](https://www.verpact.nl/nl/tarieven), consulted 2026-11-03.
21. BOE: Real Decreto 1055/2022, de envases y residuos de envases, [https://www.boe.es/buscar/act.php?id=BOE-A-2022-22690](https://www.boe.es/buscar/act.php?id=BOE-A-2022-22690), consulted 2026-11-03.
22. Verpackungsverordnung 2014, § 9 and § 13 (unofficial consolidation), [https://gesetzefinden.at/bundesrecht/verordnungen/20008902/para-9](https://gesetzefinden.at/bundesrecht/verordnungen/20008902/para-9), consulted 2026-11-03.
23. Ministry of the Environment, Luxembourg: Agrément REP N° 1/AG-EMBAL/23 (Valorlux), [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 2026-11-03.
24. Ontario ERO notice 026-1058 (27 October 2026), [https://ero.ontario.ca/notice/026-1058](https://ero.ontario.ca/notice/026-1058), consulted 2026-11-03.
25. SPI fee-market files (14 markets), with the scheme tables, general terms and reports cited in the text (CAA 2026 Colorado schedule, SPV Tabela VPV 2026, Valorlux 2026 tariff and general conditions, Ecoembes Precios 2026 and eco-modulation guide, Repak QF 509, ARA general terms, Isle of Man Treasury notice of 3 March 2026), and SPI Packaging Regulation Tracker, /data/packaging-regulation-tracker/, consulted 2026-10-14.