The EU Packaging and Packaging Waste Regulation (PPWR) entered into force in 2025 and is now being transposed into the operational reality of producers. The regulation harmonizes the design rules — recyclability classes, mandatory recycled content for plastic packaging, reuse targets for transport and grouped packaging — but it deliberately leaves the financing mechanism to member states. Extended producer responsibility schemes remain national, and the fees those schemes charge per kilogram of packaging placed on market vary by more than an order of magnitude across the bloc.

For a multi-country retailer, that variation is now material. Packaging EPR fees that were rounding error in 2020 are, in 2026, a line item that procurement and sustainability teams are actively managing. We talked to packaging compliance leads at three pan-European retail groups and pulled the current published fee schedules from the main national PROs to put together a comparison.

The five markets

We focused on France, Germany, the Netherlands, Spain, and Italy. These are the markets where EPR for packaging is most mature and where the fee structures are most clearly published. The numbers below are directional — actual fees depend on material, format, recyclability classification, and increasingly on eco-modulation bonuses and maluses — but they capture the order of magnitude that retailers are paying.

  • France (CITEO): Among the most expensive in Europe. Plastic packaging fees sit in a wide range depending on recyclability, with non-recyclable formats attracting substantial maluses on top of the base fee. Eco-modulation is aggressive and has been ratcheted up annually.
  • Germany (the dual systems via ZSVR registration): Market-based pricing across competing dual systems. Plastic film and composite materials are the most expensive categories; glass and paper are an order of magnitude cheaper. Producers can shop between systems, which keeps prices comparatively disciplined.
  • Netherlands (Verpact, formerly Afvalfonds): Mid-range overall, with a sharp eco-modulation curve that makes non-recyclable plastic packaging meaningfully more expensive than recyclable equivalents.
  • Spain (Ecoembes, with the new royal decree adjustments): Historically the lowest of the five, but fees rose materially in 2024 and again in 2025 as Spain implemented its single-use plastics tax in parallel with EPR. The combined effective cost on plastic packaging has roughly doubled.
  • Italy (CONAI): Multiple consortia by material, with fees set per material stream. Plastic fees rose sharply in the last two cycles; paper and glass remain low.

The headline gap: plastic packaging fees per kilogram in France are several times what they are in Spain or Italy for the same format, before eco-modulation. Once eco-modulation is layered in, the gap between a "good" recyclable PET bottle and a "bad" multi-material flexible pouch can be larger than the gap between countries.

Eco-modulation is the real lever

The most important shift since 2023 is the weight that eco-modulation now carries. Bonuses for verified recycled content and for designed-for-recycling formats, paired with maluses for disruptors (PVC labels on PET bottles, dark plastics, certain multi-material laminates), can move the effective fee by 50 to 100 percent on the same kilogram of packaging. France and the Netherlands have the steepest curves. Germany's dual systems vary, but the trend is the same direction.

For retailers, this means the comparison that matters operationally is not "France vs Spain" — it is "this SKU's packaging spec vs that one, across all the markets it ships into." A packaging compliance lead at a European grocery group described the work this year as "renormalizing the entire private-label pack catalog against the new modulation tables, country by country, and feeding that into the renewal cycle."

Where the money goes — and where it doesn't

A common frustration among retailers we spoke to is the disconnect between fees paid and infrastructure delivered. CSRD-driven disclosures have made it easier to see how much EPR is costing, but the recycling rates and infrastructure outcomes vary enormously. Spain's collection and sorting infrastructure has lagged the fee increases. France collects aggressive fees and has delivered measurable infrastructure investment, but recyclability rates for flexible plastics remain low everywhere.

The PPWR's 2030 design-for-recycling mandate will force convergence on what counts as recyclable, which should in turn discipline how PROs classify packaging for fee purposes. Until then, the same pack format can be classified as recyclable in one country and non-recyclable in another, with the fee consequences that implies.

Practical implications for 2026

Three things are worth doing now if you haven't already:

  • Build a country-by-country effective fee model at SKU level. Spreadsheet-and-API work, not strategy work. The data is published; the question is whether it's loaded into your packaging system of record.
  • Front-load PPWR design-for-recycling work on the worst-performing SKUs. The maluses are real, they compound, and they will only get steeper.
  • Pressure-test reuse targets. PPWR's reuse obligations for transport and grouped packaging start landing operationally in the next two cycles. Most retailers we talked to are still in pilot mode on reusable secondary packaging, and that is a 2027 problem becoming a 2026 problem.

The harmonization story is real but slow. Until it lands, EPR is one of the few areas where packaging design choices still translate directly into cash, country by country.