Lorax EPI

What is Eco-modulation and where would this lead us to?
by Jianhong Hu at 11:04 in Packaging

EU waste framework directive (amended 2018) introduced the modulation of the financial contribution to Extended Producer Responsibility (EPR) schemes. This minimises waste packaging generation and incentivises the designs with better recyclability and sustainability.

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In other words, if your packaging is easier to be collected and recycled in the local infrastructure, then it will be subject to a lower EPR fee rate while those difficult to recycle packaging will cost you more from an EPR perspective. For more information on Eco-modulation, please refer to our previous blog: Eco-modulation - what is it, and where is it being used? - Lorax EPI (Lorax-epi.com)


For the transition to a circular economy, an increasing amount of countries have introduced and implemented eco-modulation into their EPR system. However, due to the diverse nature of each country's legal framework and recycling infrastructure, the status of eco-modulation applications varies.

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Level 1 Weight-based model

A lot of countries remain on the weight-based model with high-level material categories for packaging EPR. This model focuses on promoting the source reduction of packaging waste, which means the more and heavier packaging you place on the market, the higher the EPR cost will be due.

Level 2 Modified costs for collection and recovery model

Fee categories are split down based on detailed packaging parameters such as colour, flexibility, packaging format, size, etc. This is to incentive packaging that is easier for collection and recovery.

Level 3 Circular economy based model

Additional discounts have been set up for the inclusion of recycled content, informative sorting instructions to end-users, a simpler packaging design, etc. In some countries, penalties have also been imposed on packaging components that cause disruption or contamination in the recovery process.


Eco-modulation is a continuously evolving concept with various implementations in different countries. For more information and advice on how we could help your business respond to the changes, contact Lorax EPI and speak with one of our consultants today.


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