To Top

Eco-Fee Modulation

Environmentally friendly packaging design as a key criterion

Eco-fee modulation is a concept that introduces Europe-wide fees based on the recyclability of packaging. In accordance with extended producer responsibility, licence fees are levied in stages: Through sustainable packaging design, companies can benefit from reduced fees and thus save costs. Packaging that does not fulfil the requirements of eco-modulation, on the other hand, is taxed at a higher rate than environmentally friendly packaging. Find out more about the current regulations in the various countries and how Interzero Recycling Alliance can help you to understand and implement the requirements!

Do you have questions about eco-fee modulation? Find out more about the savings you can make by utilising eco-fees. Get in touch with us!

What are the aims of eco-modulation?

The main aim of eco-fee modulation is to promote the circular economy and save primary resources. This is to be achieved by incentivising sustainable packaging solutions.

Strengthen environmental protection, save costs

Circular economy in Europe: European guidelines promote waste prevention and the closing of raw material cycles through a circular economy.

Raising awareness: Eco-modulation aims to raise awareness of environmental issues. Companies are motivated to rethink their decisions in favour of more sustainable packaging.

Promoting environmentally friendly practices: The Eco-Fee serves to encourage companies to act in an environmentally friendly way by increasing the cost of environmentally harmful behaviour.

Cost savings: Sustainable packaging is rewarded with lower licence fees. This pays off financially.

Assessment of the recyclability of packaging

Eco-modulation is intended to promote sustainable packaging design throughout Europe. One criterion that is decisive in most countries is the recyclability of packaging. Standardised benchmarks for assessing the recyclability of packaging are essential, which is why criteria and technical standards need to be defined.

Recyclability is assessed on a scale of 0-20 points. Packaging is fully recyclable if the recovery process produces high-quality recyclates that can replace primary sources.

If packaging fulfils the required criteria, it is considered ready for recycling. The actual recyclability depends on the infrastructure in the respective country. The guidelines on eco-fee modulation are intended to take national characteristics into account while ensuring that the incentives set are efficient and have a positive impact on reducing packaging waste.

All-round packaging service provider Interzero Recycling Alliance

As an experienced environmental service provider, Interzero Recycling Alliance supports almost all stages of the packaging cycle, from licensing in the relevant countries to the sorting of paper and lightweight packaging and the processing of plastics into high-quality recyclates. In addition, Interzero Recycling Alliance has a renowned centre of excellence for plastics recycling, where research and development of recycled plastics is driven forward. This centre also carries out assessments of packaging with regard to its recyclability.

In order to comply with the legal requirements of the Packaging Act, the forthcoming PPWR and eco-modulation, Interzero Recycling Alliance focuses on optimising recyclable materials. This means designing packaging in such a way that it can be recorded during collection, clearly sorted and processed into high-quality secondary raw materials. Interzero Recycling Alliance supports companies in designing packaging in such a way that it complies with sustainable principles and enables it to pass through the after-life processes effectively.

Our advantages for you

  • Uncovering potential savings

    We show you how you can save costs by making changes to the licence quantity report.

  • Legal compliance

    We show you which licence category is the right one for your packaging. So you are on the safe side when it comes to compliance issues.

  • Notes on packaging optimisation

    It may be possible to save licence fees by making small changes to the packaging. We will show you your options.

  • Eco-fee modulation

    In some European countries, eco-fee modulation is already being actively used as an incentive. We will show you in which countries this is the case and what is important.

  • Recyclability

    Recyclability plays a decisive role in licence fees. We can tell you how the recyclability of your packaging currently stands and what could be optimised.

  • Clearing up the licensing jungle

    Packaging licensing is organised differently in every country. With our analysis, we bring clarity to the different country requirements.

Eco-Fee Modulation: Recycling pioneers

Interzero Recycling Alliance has already carried out successful pilot projects as part of eco-fee modulation. Interzero Recycling Alliance analyses the packaging for the respective target markets in order to check the recyclability of the packaging. The certification can then be communicated in a legally compliant manner. In this context, it is also assessed whether there are opportunities for cost savings in relevant countries or whether the company is already classified in the best possible licence group.

The study shows in which countries eco-fee modulation has already been implemented. In addition, Interzero Recycling Alliance provides information on whether your packaging is already entitled to benefit from eco-modulation and how high the financial savings are. As a customer, you will also receive optimisation tips if the packaging does not yet have the design to benefit from the Eco-Fee. In addition to Eco-Fee modulation, recyclability is also taken into account.

Rely on Interzero Recycling Alliance as your partner for sustainable packaging solutions and participate in the future of environmentally friendly packaging.

  • A thorough analysis of your packaging portfolio will identify potential cost sources in different markets.
  • A precise forecast of the EPR costs incurred is crucial. This allows you to react early and adapt your business strategy and measures to the financial implications.
  • Interzero Recycling Alliance offers concrete recommendations for minimising costs and supports you in strengthening your competitiveness.

Eco-modulation in Europe

The aim is to standardise the implementation of the eco-fee in Europe. However, implementation in the individual countries is currently still very heterogeneous.

Under the leadership of the Federal Environment Agency, Germany is planning to introduce a fund into which the fees and fines will flow. Manufacturers are obliged to check the recyclability of their packaging. In doing so, they will be able to rely on a positive catalogue based on the minimum standards of the Central Agency Packaging Register (ZSVR). Particularly recyclable packaging is to be favoured with money from the fund, making it attractive for manufacturers to bring it onto the market.

Some countries only tax certain materials and others have not yet implemented eco-fees. Numerous changes are pending in the area of extended producer responsibility (EPR). One example of this is the previous exemption limit in Finland, which exempted companies with a turnover of less than one million euros from taxes. However, this exemption from the EPR will be abolished at the beginning of 2024. In France, the eco-fee is known as the eco-contribution, while in Switzerland the corresponding measure for glass containers is known as the advance recycling fee (vRg).

Interzero Recycling Alliance is familiar with the regulations of all countries and keeps you up to date at all times. Interzero Recycling Alliance checks whether the design of your packaging fulfils the Eco-Fee Modulation requirements for all countries you import to and distribute in. If not, we will support you in adapting your packaging to the new Eco-Modulation standards for European Packaging Licensing.

What is the difference between plastic tax and eco-fee?

The so-called plastic tax is a levy that EU member states have to pay to the European Union per kilogramme of non-recyclable plastic waste. The member states themselves decide on the implementation of the plastic tax: The tax is paid from national budgets or passed on to the distributors and manufacturers of packaging.

The eco-fee modulation does not only relate to the packaging material, but generally to whether the packaging is sustainable. The introduction of eco-modulation will differentiate the costs for packaging licensing in Europe. Non-recyclable packaging will be subject to higher fees in future. In this context, it is undoubtedly worth reorganising and focusing more on recyclability and the use of recyclates.

Analyse recyclability


Your safe way to certification!

Take advantage of our experience and Europe-wide network

1 Analysis

Determine your obligations and select the appropriate foreign licensing and take-back system based on the data you provide and quantities placed on the market.

2 Processing

Handling of the entire contract management and associated correspondence with the foreign systems, including execution of the legally prescribed, timely quantity reports and further reporting.

3 Compliance Service

The identification of open issues and the development of measures to maintain your compliance.