# Six euro schemes send six different price signals on rigid plastic, and a full sleeve on a clear PET bottle costs 10% more in Spain but 12 times more in Belgium

> In 2026 a clear PET bottle pays between EUR 249.8 per tonne (Valorlux, Luxembourg) and EUR 1,220.0 before discounts (Verpact, the Netherlands), but the bigger difference is how each scheme reacts to colour, polymer and disruptive design: Fost Plus prices a coloured PET bottle at 3.5 times a clear one, CONAI charges clear, coloured and opaque PET bottles the same, Citeo and Ecoembes add percentage maluses, and Verpact takes up to EUR 0.40 per kg off for design in 2027.

Publisher: Strategic Packaging Insights  
Published: 2026-10-28  
Last updated: 2026-10-28  
Page: https://www.strategicpackaginginsights.com/insights/rigid-plastic-epr-fees-pet-colour-polymer-euro-schemes/

**In 2026 a clear PET bottle pays between EUR 249.8 per tonne (Valorlux, Luxembourg) and EUR 1,220.0 before discounts (Verpact, the Netherlands), but the bigger difference is how each scheme reacts to colour, polymer and disruptive design: Fost Plus prices a coloured PET bottle at 3.5 times a clear one, CONAI charges clear, coloured and opaque PET bottles the same, Citeo and Ecoembes add percentage maluses, and Verpact takes up to EUR 0.40 per kg off for design in 2027.**

On SPI's worked basket of 1 million cooking oil bottles and 1 million food trays, the design-for-recycling version costs EUR 16,600.85 in Spain and EUR 34,440.00 in the Netherlands in 2026, while the worst version tested costs 4.63 times its clean version in Belgium and 1.17 times in Spain. All six schemes publish in euro, so their figures are set side by side here, with differences in fee base stated.

## Executive summary

Rigid plastic is where packaging fee tables are most detailed, because bottles, trays, tubs and caps are sorted by polymer and colour. This piece reads the rigid plastic lines and the design rules of six euro schemes from their own 2026 and 2027 documents, consulted on 28 October 2026: Citeo in France, CONAI with its plastic consortium Corepla in Italy, Ecoembes in Spain, Verpact in the Netherlands, Fost Plus in Belgium and Valorlux in Luxembourg.

The headline is that the six do not send the same signal. Belgium and Luxembourg build colour and polymer into separate rate lines, so a coloured PET bottle pays 3.49 times a clear one at Fost Plus and 1.50 times at Valorlux (Exhibit 1). Italy groups packs into recyclability bands, and its PET band B1.2 holds clear, coloured and opaque bottles alike at EUR 304 per tonne. France and Spain start from a base rate and add percentage maluses, from 10% at Ecoembes to 100% at Citeo. The Netherlands charges every rigid plastic EUR 1.220 per kg and then gives discounts for design.

What is penalised is broadly agreed: full sleeves that hide the bottle from sorting machines, carbon black that near infrared sorters cannot read, PVC, silicone and metal parts on PET, and multilayer structures. How hard it is penalised is not. On the same clear PET bottle, a full non-perforated sleeve raises the fee by about 10% in Spain, 24% in the Netherlands, 50% in France, 182% in Italy and 1,126% in Belgium (Exhibit 7).

On SPI's worked basket, 1 million 1-litre PET cooking oil bottles and 1 million clear PET food trays, the clean design costs EUR 16,600.85 at Ecoembes and EUR 34,440.00 at Verpact in 2026 (Exhibit 8). Changing to a green bottle and a carbon black PP tray, or adding a sleeve and a multilayer tray, raises the Belgian bill from EUR 27,932.80 to as much as EUR 129,397.80, while the Spanish bill moves by at most 17% (Exhibit 9).

For leaders, three moves matter most. Price every rigid SKU by design feature in each market, not by polymer alone; remove full non-perforated sleeves and carbon black first, because they are the features that every scheme penalises; and budget for the 2027 changes now, including Fost Plus's split between mono and multilayer PET trays and Verpact's new two-part plastic discount.

## Key findings

1. In 2026 a clear PET bottle pays EUR 249.8 per tonne at Valorlux, EUR 260.0 at Ecoembes, EUR 304.0 at CONAI (from 1 October 2026), EUR 360.4 at Fost Plus, EUR 700.0 at Citeo and EUR 1,220.0 at Verpact before its discount, all excluding VAT (scheme tables, consulted 28 October 2026).
2. **SPI analysis:**  a transparent green PET bottle costs 3.49 times a clear one at Fost Plus and 1.50 times at Valorlux, but 1.05 times at Citeo and the same at CONAI and Ecoembes, where colour only removes a small bonus.
3. A full non-perforated sleeve takes a clear PET bottle to EUR 4,419.0 per tonne in Belgium (obstructive category D006), to CONAI band B2.2 at EUR 856, and to a 50% malus at Citeo, against a 10% malus at Ecoembes (Fost Plus 2026 rates; CONAI plastic list, March 2026 update; Citeo guide 2026; Ecoembes guide 2026).
4. For 2027 Fost Plus separates multilayer from mono PET trays, raising multilayer 32.1% to EUR 1,525.2 per tonne while mono rises 1.9% to EUR 1,177.1, and Valorlux raises every rigid plastic line, from 7.5% for dark blue or green PET bottles to 68.8% for EPS (Fost Plus and Valorlux 2027 tables).
5. Verpact splits its plastic discount for 2027 into a Design for Recycling scheme of four EUR 0.10 per kg steps, capped at EUR 0.40, and a separate Circulaire Plastics scheme; its tariff page says the two together can reach EUR 1.18 per kg (Verpact, September 2026).
6. **SPI calculation:**  SPI's clean basket costs EUR 16,600.85 in Spain, EUR 18,565.60 in Luxembourg, EUR 21,875.00 in Italy, EUR 27,932.80 in Belgium, EUR 31,641.70 in France and EUR 34,440.00 in the Netherlands in 2026; the worst version tested costs 4.63 times the clean one in Belgium and 1.17 times in Spain.

## Four ways to price a rigid plastic pack

Before comparing numbers, it helps to see that the six schemes use four different devices to reward or penalise design (Exhibit 2). The [EPR fees per tonne piece](https://www.strategicpackaginginsights.com/insights/epr-fees-per-tonne-2026/) groups 14 markets by what drives a whole basket; this framework narrows the lens to rigid plastic and asks one question: where in the fee does design enter?

**Architecture A, coded lines.**  Fost Plus and Valorlux publish separate rates for clear, blue, other coloured and opaque PET bottles, for PET trays, and for HDPE, PP and PS rigid packaging. There is no percentage on top. The strength of the signal depends on the gap between lines and on the penalty line: EUR 4,419.0 per tonne at Fost Plus, which covers non-recyclable and obstructive packaging, against EUR 1,483.0 for PV15 other non-recoverable packaging at Valorlux.

**Architecture B, bands.**  CONAI's plastic list places each pack and each component in one of nine bands. Bands A1.1 to A2 cover commercial and industrial packaging, B1 household packs with a consolidated chain, B2 those still consolidating or experimental, and C packs that cannot be sorted or recycled with current technology. The [Italy piece](https://www.strategicpackaginginsights.com/insights/italy-conai-fee-bands-explained/) walks through the bands one by one; here the point is that colour is not a band criterion for PET bottles, while sleeves, printing and multilayers are.

SPI analysis

The architecture matters more than the headline rate. A brand that reads only the rate for its polymer will miss most of the cost of a bad design in Belgium, where the penalty is a different line, and will overstate the Dutch cost of a good design, where the discount sits outside the rate table.

## PET bottles: clear, coloured and opaque

Exhibit 3 sets out the PET bottle lines in each scheme for three designs, using each scheme's effective 2026 and published 2027 rate for a bottle with no disruptive features. Where a scheme modulates by percentage or discount, the effective rate is shown; the note gives the base.

**Belgium.**  Fost Plus splits PET bottles and flasks into four lines in 2026: transparent colourless at EUR 0.3604 per kg, transparent blue at EUR 0.5527, transparent other colours at EUR 1.2568 and opaque at EUR 0.8776. Its 2026 sheet says colourless PET has no added colouring pigment, and that the colour should be checked at the injection point or the neck; opaque PET is packaging whose content is not or barely visible through the material. For 2027 the clear line holds at EUR 0.3604, blue falls to EUR 0.5324, other colours fall 17.7% to EUR 1.0346 and opaque falls 4.8% to EUR 0.8355. The ratio of coloured to clear therefore eases from 3.49 to 2.87.

**Luxembourg.**  Valorlux has five PET bottle lines once its PET tray line is counted: PV06 transparent colourless or light blue at EUR 0.2498 per kg in 2026, PV07 dark blue or green at EUR 0.3739, PV08 other colours at EUR 0.4857 and PV09 opaque at EUR 0.4871. The 2026 table raised coloured and opaque PET by about 60% on 2025 (SPI fee-market notes). The 2027 table, approved at the October 2026 general assembly, raises PV06 by 10.4% to EUR 0.2758, PV07 by 7.5% to EUR 0.4019 and PV08 and PV09 by 18.0% to EUR 0.5731 and EUR 0.5749.

**Italy.**  CONAI's March 2026 list puts in band B1.2 PET bottles and jars of transparent or coloured transparent monopolymer PET without a covering label or direct printing, opaque PET bottles and jars, and PET bottles with a perforated covering label that carries removal instructions. All pay EUR 304 per tonne from 1 October 2026, up from EUR 228. Colour does not move a PET bottle out of B1.2; carbon black does, because containers of up to 5 litres with carbon black fall into band C.

**France.**  Citeo's 2026 guide lists 6.1, clear PET bottle or flask, at 70.00 euro cents per kg (EUR 700.0 per tonne) and 6.2.3, dark or coloured PET bottle or flask, at 73.51 cents (EUR 735.1). It removed the malus on opaque rigid PET for 2026, giving the reason that the evolution of recycling no longer justifies it. The guide names no separate opaque line, so SPI has not yet confirmed whether an opaque bottle is declared under 6.2.3.

**Spain.**  Ecoembes prices PET by format, not colour: drinks bottles of up to 3 litres in the SUP line at EUR 0.271 per kg, other PET bottles at EUR 0.260 and PET trays and other rigid PET at EUR 0.659 in 2026. Colour enters through the eco-modulation guide. A PET bottle that is transparent or light blue earns 0.43%, and recycled PET above 25% earns another 0.43%; an opaque bottle pays a 10% malus that cancels any bonus.

**The Netherlands.**  Verpact's colour step is worth EUR 0.10 per kg. For PET it requires natural or colourless material, with a very small amount of blue allowed to mask yellowing, across at least 90% of the target material's weight. White counts for PE and PP but not for PET, so a white opaque PET bottle loses the step.

SPI analysis

A brand moving a range from green to clear PET saves EUR 896.4 per tonne in Belgium in 2026 and EUR 674.2 in 2027, EUR 124.1 per tonne in Luxembourg in 2026, EUR 100.0 in the Netherlands, EUR 35.1 in France, EUR 1.1 in Spain and nothing in Italy. Belgium alone makes the colour decision a fee decision; elsewhere the case for clear PET rests on recyclate value and the coming PPWR grades.

## Polymer choice: HDPE, PP, PS and PET trays

Exhibit 4 compares the rigid lines other than PET bottles. For a tray, tub or pot the polymer is often a real choice, so the gaps here are where design budgets can earn back their cost.

**PET trays are priced as a separate problem.**  In five of the six schemes a clear PET tray pays more than a clear PET bottle of the same polymer: 1.20 times at Citeo, 3.02 times at CONAI, 2.53 times at Ecoembes, 3.20 times at Fost Plus and 3.12 times at Valorlux (SPI calculation from Exhibits 3 and 4). Only Verpact charges both at EUR 1.220. The reason is the recycling route: trays are thermoformed with different melt properties from bottle grade PET, and CONAI's list places clear thermoformed PET trays and blisters in band B2.3, its experimental chain, at EUR 917 per tonne. Valorlux created a separate PV14d PET tray line in its 2026 table at EUR 0.7806 per kg; its 2027 table prints EUR 0.7806 and EUR 0.8328 against a three-year header, which SPI reads as EUR 0.8328 for 2027, a reading SPI has not yet confirmed with Valorlux.

**PP against PET for trays.**  A natural PP tray is cheaper than a clear PET tray at Citeo (EUR 770.1 against EUR 840.1), CONAI (EUR 639 against EUR 917), Fost Plus (EUR 1,016.1 against EUR 1,154.6) and Valorlux (EUR 427.9 against EUR 780.6). At Ecoembes the order reverses, with other rigid plastics at EUR 0.748 per kg against EUR 0.659 for PET trays, and at Verpact the two are equal. A tray buyer serving all six markets therefore cannot pick one polymer that is cheapest everywhere.

**PS and EPS.**  Italy prices rigid non-foam PS with PET trays in band B2.3 at EUR 917, well above PP at EUR 639. Fost Plus charges rigid PS EUR 1,000.7 per tonne, close to its PP line, and EPS EUR 1,232.5 in 2026, rising to EUR 1,058.6 and EUR 1,937.3 in 2027. Valorlux charges rigid PS EUR 437.2 and EPS only EUR 209.4 per tonne in 2026, though EPS rises 68.8% to EUR 353.4 in 2027. Citeo has no PS-specific malus; its line 6.5 covers rigid PS including XPS and EPS at 80.51 cents per kg.

**The 2027 polymer moves.**  Fost Plus raises rigid PP 12.3% to EUR 1,140.9 and rigid PE 4.8% to EUR 840.3 for 2027. Valorlux raises HDPE 23.4% to EUR 377.3, PP 15.9% to EUR 495.8 and PS 21.2% to EUR 530.1. Ecoembes moves HDPE down 1.1% to EUR 282 and other rigid plastics up 3.3% to EUR 773. Verpact holds its rigid rate.

SPI analysis

For trays and tubs, the polymer decision is market-specific and moves the bill by 9% to 82% within a scheme, while for bottles the polymer is usually fixed and the design details matter more. The [carton piece](https://www.strategicpackaginginsights.com/insights/beverage-carton-epr-fees-austria-benelux-portugal/) found carton lines at 75% to 101% of each scheme's rigid plastic line, so a switch from a PP tub to a carton is rarely a fee saving by itself.

## The malus layer: sleeves, carbon black, PVC and multilayers

The features that disrupt recycling are much the same in every scheme. Exhibit 5 lines up how each one is penalised.

**France sets the strongest percentages.**  Citeo raised five maluses for 2026 and removed five (SPI fee-market notes). Three that touch rigid plastic went from 10% in 2025 to 50% in 2026: PE or PP rigid packaging above density 1, PET combined with a rigid plastic above density 1 such as a POM part, and PET bottles with a non-perforated sleeve in PETG, PLA or PS, where separating the sleeve does not avoid the malus. Two carry 100%: rigid PET packs combined with aluminium, PVC or silicone above density 1, and dark rigid plastics not detectable by optical sorting, with exemptions where the dark surface is under 50% of the visible surface, only the cap is dark, or the colourant is validated by COTREP. Maluses of the same level do not add up, but maluses of different levels can, and a unit with a recycling disruptor malus cannot receive any bonus (Citeo guide 2026, pp. 30 and 31).

**Spain caps the malus at 10%.**  Ecoembes applies one 10% surcharge on the main element when any trigger is present, and the presence of a penalised element cancels all bonuses. The triggers for PET bottles are an opaque colour, multimaterial construction including EVOH of 5% or more, a label of another material covering two thirds or more of the body unless it is designed for forced removal or carries a separation legend, and PVC, rubber, silicone or metal accessories. For trays, colour and opacity are maluses rather than missed bonuses.

**Belgium uses its penalty line.**  Fost Plus's last derogations for obstructive packaging expired on 31 December 2025, so from 2026 every obstructive item pays the highest rate and must use a detailed declaration (SPI fee-market notes). Its 2026 sheet lists 18 obstructive categories. For rigid plastic the key ones are D006, plastic bottles at least 70% covered by a sleeve, or 50% for bottles under 50 cl, where the sleeve is a different material and not perforated, and D012, coloured plastic packaging with carbon black pigments. PVC, PVdC and PETG sit in code 014-03, other valorised plastics, at the same EUR 4.4190 per kg.

**Italy uses its top bands.**  CONAI's general rules put PVC in packaging or components in band C outside the commercial A1 bands, move visible carbon black colouring to band C, tolerate mineral fillers only below 1 g per cm3, and limit EVOH to 5% of the pack's weight in the B2 bands where it is allowed. Anything not on the list falls into band C. From 1 October 2026, band C is EUR 922 per tonne, only EUR 5 above B2.3.

SPI analysis

For a single feature such as a sleeve, the cost of getting it wrong varies by a factor of more than 100 across the six schemes, from about EUR 27 per tonne in Spain to EUR 4,058.6 per tonne in Belgium. A design rule set to pass Belgium and France will pass the other four on these features; the reverse is not true.

## The bonus layer: mono-material and other design rewards

On the reward side the schemes diverge more. Exhibit 6 sets out what a clean rigid pack can earn.

**Verpact's 2026 conditions.**  To earn any design step a unit must be more than 50% plastic by weight and at least 70% target material, rigid units must be over 3 cm and up to 5 litres, and the four steps each have their own test (Regeling Tariefdifferentiatie Plastic 2026). Mono-material means at least 95% PET, PE or PP for rigid packs, with up to 5% additives such as barriers, coatings and inks, and rigid PET may contain no layers of other materials. The labels step requires PE or PP labels and sleeves with no other layers, covering no more than 50% of a unit under 500 ml or 70% above. The fourth step requires the final rating goed recyclebaar in the current year's Recyclecheck.

**Verpact's 2027 split.**  The September 2026 document for 2027 keeps the four design steps at EUR 0.10 per kg and a cap of 40 euro cents per kg, and moves recycled content and biobased drop-ins into a separate Circulaire Plastics scheme that can be applied alongside it. The tariff page says a producer can receive up to EUR 1.18 per kg off the plastic contribution in 2027 for design for recycling and the use of recyclate or biobased drop-ins. SPI has not yet confirmed the step values in the Circulaire Plastics scheme. The same page adds a new 2027 line, plastic drinks bottles without deposit, at EUR 2.600 per kg, more than twice the rigid rate; SPI has not yet confirmed which bottles fall in it.

**Belgium's 2027 change.**  Fost Plus already separated mono and multi transparent PET rigid elements other than bottles in 2026, as codes 011-05-A and 011-05, but charged both EUR 1.1546 per kg. Its 2027 table prices them apart: mono rises 1.9% to EUR 1.1771 and multi 32.1% to EUR 1.5252. The 2026 sheet defines mono as at least 95% mono APET, excluding inks, adhesives and glues, and multi as transparent thermoformed multilayer PET such as APET/PE or APET/PE-EVOH-PE.

In practice: Fost Plus.

Fost Plus noted for 2025 that opaque PET trays left the non-recyclable category and gained their own rate (SPI fee-market notes), and in 2026 that line, 011-08 opaque thermoformed rigid PET, is EUR 1.1931 per kg. For 2027 it falls 0.8% to EUR 1.1838, so an opaque PET tray costs less than a clear multilayer one in 2027. SPI calculation: on 15,000 kg of trays, moving from multilayer to mono PET saves EUR 5,221.50 on Fost Plus's 2027 rates and nothing on its 2026 rates.

## How hard each scheme hits one disruptive feature

To isolate the signal, SPI took a single clear PET bottle and added one feature: a full non-perforated sleeve in a different plastic. Exhibit 7 divides the effective rate with the sleeve by the effective rate without it, inside each scheme.

The same test on a tray gives a similar order. A carbon black PP tray costs 4.35 times a natural PP tray in Belgium (EUR 4,419.0 against EUR 1,016.1), 2.00 times in France (100% malus), 1.44 times in Italy (band C against B2.1), 1.24 times in the Netherlands on SPI's step assumptions, and 1.14 times in Spain (10% malus against a 3.86% colour bonus). Valorlux's table again has no carbon black rule that SPI has read.

SPI analysis

The multiplier explains behaviour. In Belgium and Italy a sleeve or a black tray is a pricing event large enough to justify a line change mid-year; in Spain it is close to rounding. Brands that set packaging specifications centrally should design to the strictest multiplier in their footprint, not to the average.

## Worked example: one bottle and one tray

SPI priced one basket through all six schemes (Exhibit 8): 1 million 1-litre PET cooking oil bottles at 25 g each with a 2 g HDPE cap, and 1 million clear mono PET food trays at 15 g each. All weights are SPI assumptions. A cooking oil bottle is used so that drinks rules do not apply: no deposit system, no SUP lines, no Citeo small-format drinks malus and no Dutch SUP component. Labels are left out of the weights. That gives 25,000 kg of PET bottle, 2,000 kg of HDPE cap and 15,000 kg of PET tray.

**Method.**  Each line is kilograms times the scheme's rate per kg, or tonnes times the rate per tonne in Italy. France: 25,000 x 0.7000 = EUR 17,500.00; 2,000 x 0.7701 = EUR 1,540.20; 15,000 x 0.8401 = EUR 12,601.50. Italy: 25 x 304 = EUR 7,600; 2 x 260 = EUR 520; 15 x 917 = EUR 13,755. Spain: 25,000 x 0.260 x 0.9957 = EUR 6,472.05; 2,000 x 0.285 = EUR 570.00; 15,000 x 0.659 x 0.967 = EUR 9,558.80. Netherlands: the bottle unit, bottle plus cap, is 27,000 kg x (1.220 minus 0.40) = EUR 22,140.00, so the cap column shows n/a; trays 15,000 x 0.820 = EUR 12,300.00. Belgium: 25,000 x 0.3604, 2,000 x 0.8019 and 15,000 x 1.1546. Luxembourg: 25,000 x 0.2498, 2,000 x 0.3058 and 15,000 x 0.7806.

**Where fee bases differ.**  Citeo also charges per-unit parts on each sales unit and applies its percentages to the total, so the French figure is a floor. CONAI's fee is charged at the first transfer from converter to user, so in Italy it usually arrives on the packaging supplier's invoice; the same purchase before 1 October 2026 would have cost EUR 17,913.00 at the January rates. Spain's state tax on non-recycled plastic packaging sits on top of the Ecoembes fee and is covered in the [plastic taxes piece](https://www.strategicpackaginginsights.com/insights/plastic-packaging-taxes-2026/). Verpact's figure assumes the producer is above its 50,000 kg threshold.

SPI analysis

The tray, 36% of the plastic weight, is 63% of the Italian bill and 62% of the Belgian bill, but 40% of the French one. For a mixed range, the tray is where the fee sits in Italy and Belgium, and the bottle is where it sits in France.

## Three designs, one basket

To show how design moves the bill, SPI priced the same basket in three versions (Exhibit 9). The clean version is Exhibit 8. The colour version changes the bottle to transparent green PET and the tray to a carbon black PP tray of the same weight. The disruptive version keeps the clear bottle but adds a full non-perforated PETG sleeve, whose own weight is left out, and changes the tray to a clear multilayer PET/PE tray.

**Reading the colour column.**  In France the carbon black tray doubles the tray line to EUR 23,103.00 and the green bottle adds EUR 877.50, for a bill of EUR 43,020.70. In Italy the colour version barely moves, by EUR 75, because a green bottle stays in B1.2 and a black PP tray at EUR 922 replaces a clear PET tray at EUR 917. In Belgium the green bottle adds EUR 22,410.00 and the black tray EUR 48,966.00. In Luxembourg the bill falls by EUR 2,188.00, because a PP tray on line PV12 at EUR 0.4279 per kg costs less than a PET tray on PV14d at EUR 0.7806, more than offsetting EUR 3,102.50 extra on the green bottle.

**Reading the disruptive column.**  The sleeve does most of the damage. In Belgium it moves 25,000 kg from EUR 0.3604 to EUR 4.4190 per kg, adding EUR 101,465.00. In Italy the sleeved bottle and its cap move to B2.2, adding EUR 14,992.00, and the multilayer tray adds EUR 75. In France the 50% malus on the bottle and cap adds EUR 9,520.10.

SPI analysis

Two of the six schemes, Belgium and Italy, account for most of the design premium in this basket. In Belgium the sleeve alone adds EUR 101,465.00, 3.63 times the whole clean Belgian basket, which makes D006 the most expensive single design rule in this comparison.

## Scenarios: the 2027 tables

Four of the six schemes have published 2027 rigid plastic values: Ecoembes, Verpact, Fost Plus and Valorlux. Exhibit 10 reprices the three designs where 2027 values exist. CONAI's fee table shows no 2027 plastic column, and SPI has not yet confirmed Citeo's 2027 rates from Citeo's own document.

**Belgium and Spain.**  The Spanish clean basket rises 3.0%, mainly from the tray line. The Belgian clean basket rises EUR 414.30, from higher HDPE and mono PET tray rates. The colour version falls EUR 5,478.20 because coloured PET bottles fall 17.7%. The disruptive version rises EUR 5,635.80, of which EUR 5,559.00 is the multilayer tray moving to EUR 1.5252 per kg.

**Luxembourg.**  Every version rises, by EUR 1,576.00 for the clean basket and EUR 1,861.50 for the colour version, because Valorlux raises every rigid line for 2027.

**The Netherlands.**  The design-only figure is flat because Verpact holds the rigid rate and keeps the design cap at EUR 0.40. If a producer also qualifies under Circulaire Plastics, the 2027 bill could fall further; at the full EUR 1.18 per kg that the tariff page cites, the discount would be 96.7% of the rigid rate, but SPI has not yet confirmed how the combined figure is reached.

**France.**  Citeo's stakeholder committee approved the 2027 eco-modulation proposal on 8 June 2026 (Comité des Parties Prenantes opinion). A consultancy summary reports a 2027 guide dated 30 September and revised on 8 October 2026, but Citeo's own tariff page, consulted on 28 October 2026, lists only the 2026 guide, so this piece uses no 2027 French rates.

## The EU layer: grades will reach fees after 2030

The PPWR, Regulation (EU) 2025/40, sits above all six tables. The [SPI Regulation Tracker](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/) holds its recyclability rule as [PR-EU-010](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-010/). Article 6(1) states that all packaging placed on the market shall be recyclable, and the Commission reads it as applying from 12 August 2026. The design for recycling test in Article 6(2)(a) applies from 1 January 2030 at the earliest, later if the Article 6(4) delegated acts arrive after 1 January 2028. Recyclability will be graded A, B or C, packaging below grade C will count as technically non-recyclable, and the floor rises to grade B from 1 January 2038 (recital 28). Recital 35 says the same grades are meant to modulate producer fees under harmonised criteria, without setting fee amounts.

SPI analysis

The features penalised in Exhibit 5 are the ones most likely to cost a grade, because they all reduce the share of a pack that sorting and recycling recover. A brand that removes them for fee reasons now is also preparing for the 2030 test. The opposite case is colour: Belgium and Luxembourg price colour heavily, but SPI has not yet confirmed how much a transparent coloured PET bottle will lose in grade terms once the criteria are adopted. The [recycled content piece](https://www.strategicpackaginginsights.com/insights/ppwr-recycled-content-targets-2030-2040/) covers the separate PPWR targets for recycled plastic.

## Industry reaction

> "Verpact zal in 2027 wederom goed recyclebare verpakkingen belonen."
>
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> **Verpact** , Dutch packaging producer responsibility organisation, [Tarieven](https://www.verpact.nl/nl/tarieven), consulted 28 October 2026
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> "Las penalizaciones no son acumulables y la presencia de un elemento penalizable anula todas las bonificaciones."

In English: "In 2027 Verpact will again reward packaging that is easy to recycle."

In English: "Penalties do not add up, and the presence of a penalised element cancels all bonuses."

***Ecoembes** , Spanish packaging producer responsibility organisation, [Guía de ecomodulación 2026](https://ecoembesempresas.com/app/uploads/2025/06/guia-ecomodulacion-2026.pdf), consulted 28 October 2026*

For a Spanish tray that has earned a 6.6% mono-material and recycled content bonus, one opaque or coloured element therefore swings the fee by 16.6 points.

> "Revenues that Fost Plus generates from the sale of the materials are also taken into account."

***Fost Plus** , Belgian packaging producer responsibility organisation, [Packaging EPR rates](https://www.fostplus.be/en/members/green-dot-rates), consulted 28 October 2026*

That sentence explains the colour gap in Belgium: clear PET bales sell for more than coloured or opaque ones, so the clear line carries less net cost. CONAI gave a similar cost explanation for its 1 October 2026 plastic increase, saying in its release of 25 May 2026 that demand is weak for some recycled materials, about 34% of what it handles and mainly packaging in bands B2 and C.

In practice: CONAI and Corepla.

The 1 October 2026 increase raised band B1.2 by 33.3%, from EUR 228 to EUR 304 per tonne, and band B2.3 by 16.8%, from EUR 785 to EUR 917 (CONAI fee table). SPI calculation: on the worked basket, the Italian clean bill rose from EUR 17,913.00 to EUR 21,875.00, or 22.1%, without any change to the packs.

In practice: Citeo.

Citeo's 2026 guide moved in both directions on rigid plastic: it raised three maluses from 10% to 50% and removed the opaque PET malus and the PVC bottle malus, saying the PVC tariff on its own now acts as a malus. Its plastic weight rates rose by 30.8% on most lines for 2026, with the clear PET bottle up from EUR 535.2 to EUR 700.0 per tonne (SPI fee-market notes).

## What leaders should do now

1. **Packaging and compliance teams, by 31 December 2026:**  map every rigid plastic SKU to its line, band or malus trigger in each of the six schemes, element by element, including caps, labels and sleeves, using Exhibits 3 to 6 as a checklist.
2. **Brand and design teams, at the next artwork cycle:**  replace full non-perforated sleeves on PET bottles with perforated sleeves or PE and PP labels within the coverage limits, and remove carbon black from rigid trays; these are the two features every scheme penalises.
3. **Tray buyers, before 2027 contracts close:**  check whether trays are mono or multilayer PET and whether PP is cheaper in each market, because Fost Plus prices multilayer PET 29.6% above mono PET in 2027 and Valorlux charges a PET tray 1.68 times a PP tray in 2027.
4. **Finance teams, by 30 November 2026:**  load the 2027 rigid rates of Fost Plus, Valorlux, Ecoembes and Verpact into budgets now, and hold an open line for Citeo until its 2027 guide is confirmed and for any 2027 CONAI change.
5. **Dutch commercial teams, before the 1 April 2027 declaration:**  collect the evidence for each Verpact discount step, supplier specifications, photos and Recyclecheck results, and keep it for seven years, as the scheme requires.
6. **Sustainability teams, by 1 January 2028:**  prepare recyclability evidence for the PPWR criteria act, starting with the coloured, opaque and multilayer packs that the fee tables already flag.

## Questions for your board

- What do we pay per tonne of rigid plastic in each of our markets, split by clear PET, coloured or opaque PET, PET trays, PP, PE and PS?
- Which of our SKUs carry a sleeve, carbon black, PVC, silicone or a multilayer, and what does each cost us in Belgium, France and Italy?
- Is our tray polymer the cheapest in each market, or are we using one specification across all six?
- How much Verpact discount did we claim for 2026, and are we ready for the two-part scheme in 2027?
- Which of our coloured PET bottles could move to clear, and what would we save in Belgium and Luxembourg?

## What to watch

- **November 2026:**  confirmation of Citeo's 2027 household packaging tariff and eco-modulation in a Citeo document.
- **1 Jan 2027:**  2027 tables apply at Fost Plus, Valorlux, Ecoembes and Verpact, including Fost Plus's mono and multilayer PET tray split and Verpact's EUR 2.600 per kg line for plastic drinks bottles without deposit.
- **1 Jan 2027:**  Verpact's Design for Recycling and Circulaire Plastics schemes replace the single 2026 plastic discount scheme.
- **Early 2027:**  any CONAI announcement of plastic band values or list changes for 2027.
- **1 Apr 2027:**  Verpact deadline for 2026 declarations and discount claims.
- **1 Jan 2028:**  the PPWR delegated act on design for recycling criteria and grades is expected ([PR-EU-010](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-010/)).
- **1 Jan 2030:**  earliest date for PPWR recyclability grades to apply.

## Methodology

- **Data used:**  the 2026 and 2027 tariff and eco-modulation documents of the six schemes, consulted 28 October 2026; SPI fee-market notes (data as of 14 October 2026) and calculator rows for the same schemes; Regulation Tracker rule [PR-EU-010](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-010/).
- **Counting rules:**  rates in EUR per tonne excluding VAT (per-kg rates x1000), household packaging, before thresholds, minimum fees and per-unit parts unless stated. Effective rates apply the scheme's own bonus, malus or discount to the base rate. All six schemes are in euro, so totals are set side by side, with differences in fee base stated.
- **Worked example:**  25 g PET bottles, 2 g HDPE caps and 15 g PET or PP trays, 1 million of each, are SPI assumptions. Verpact steps assume each condition is met or lost as stated in the exhibit notes. Ecoembes lines are matched by position in its PDF tables; the other rigid plastics line at EUR 0.748 per kg in 2026 and EUR 0.773 in 2027 is SPI's reading.
- **Cut-off:**  28 October 2026.
- **Limitations:**  Citeo's 2027 rates, the French line for opaque PET, CONAI's 2027 plastic values, Valorlux's PV14d 2027 value and design rules, Verpact's Circulaire Plastics steps and the scope of its 2027 drinks bottle line are not confirmed. The estimates are not invoices; confirm obligations with each scheme and check with counsel where it applies.

## Sources

1. Citeo, Guide du tarif des emballages ménagers mis en marché en 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 2026-10-28.
2. Citeo, Téléchargement des tarifs emballages et papiers, [https://www.citeo.com/telechargement-des-tarifs-emballages-et-papiers/](https://www.citeo.com/telechargement-des-tarifs-emballages-et-papiers/), consulted 2026-10-28.
3. Citeo, Avis du Comité des Parties Prenantes de la filière des emballages ménagers et papiers graphiques, 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 2026-10-28.
4. CONAI, EPR Fee (Contributo Ambientale CONAI), value table 2026, [https://www.conai.org/en/companies/services-for-managing-consortium-obligations-and-business-opportunities/epr-fee/](https://www.conai.org/en/companies/services-for-managing-consortium-obligations-and-business-opportunities/epr-fee/), consulted 2026-10-28.
5. CONAI, List of plastic packaging by fee band, valid from 1 January 2026, update of March 2026, [https://www.conai.org/wp-content/uploads/dlm_uploads/2026/08/List-plastic-packaging_fee-bands_1-January-2026_update-March.pdf](https://www.conai.org/wp-content/uploads/dlm_uploads/2026/08/List-plastic-packaging_fee-bands_1-January-2026_update-March.pdf), consulted 2026-10-28.
6. 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 2026-10-28.
7. Ecoembes, Precios 2026, envases domésticos y comerciales, [https://ecoembesempresas.com/app/uploads/2025/06/Ecoembes_Precios2026.pdf](https://ecoembesempresas.com/app/uploads/2025/06/Ecoembes_Precios2026.pdf), consulted 2026-10-28.
8. Ecoembes, Precios 2027, envases domésticos y comerciales, [https://ecoembesempresas.com/app/uploads/2026/08/Ecoembes_Precios2027.pdf](https://ecoembesempresas.com/app/uploads/2026/08/Ecoembes_Precios2027.pdf), consulted 2026-10-28.
9. Ecoembes, Guía de ecomodulación 2026, [https://ecoembesempresas.com/app/uploads/2025/06/guia-ecomodulacion-2026.pdf](https://ecoembesempresas.com/app/uploads/2025/06/guia-ecomodulacion-2026.pdf), consulted 2026-10-28.
10. Verpact, Tarieven (2025 to 2027), [https://www.verpact.nl/nl/tarieven](https://www.verpact.nl/nl/tarieven), consulted 2026-10-28.
11. Verpact, Regeling Tariefdifferentiatie Plastic 2026, [https://www.verpact.nl/sites/default/files/2026-08/Regeling%20Tariefdifferentiatie%20Plastic%202026.pdf](https://www.verpact.nl/sites/default/files/2026-08/Regeling%20Tariefdifferentiatie%20Plastic%202026.pdf), consulted 2026-10-28.
12. Verpact, Regeling Tariefdifferentiatie Plastic 2027, Design for Recycling (September 2026), [https://www.verpact.nl/sites/default/files/2026-09/VRP_Tariefdifferentiatie_DesignforRecycle_2.pdf](https://www.verpact.nl/sites/default/files/2026-09/VRP_Tariefdifferentiatie_DesignforRecycle_2.pdf), consulted 2026-10-28.
13. 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 2026-10-28.
14. 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 2026-10-28.
15. Valorlux, Grüner Punkt Tarife 2026, detaillierte Meldung (GV Oktober 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 2026-10-28.
16. 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), consulted 2026-10-28.
17. EPR Representative, Barème emballages ménagers 2027: Citeo vs Léko comparés, [https://eprrepresentative.com/blog/bareme-emballages-menagers-2027-citeo-leko](https://eprrepresentative.com/blog/bareme-emballages-menagers-2027-citeo-leko), consulted 2026-10-28.
18. SPI Regulation Tracker, rule PR-EU-010 (PPWR recyclability), /data/packaging-regulation-tracker/european-union/, consulted 2026-10-28.
19. SPI EPR & Plastic Tax Calculator and SPI fee-market notes for France, Italy, Spain, the Netherlands, Belgium and Luxembourg, /data/epr-plastic-tax-calculator/, consulted 2026-10-28.