EPR fees: what converters need to know and how to prepare

The Packaging and Packaging Waste Regulation (PPWR) has now entered into force in the European Union. One of the changes it will bring is a more harmonized approach to extended producer responsibility (EPR) schemes for packaging across the EU. This will require adaptation across the packaging value chain, from design and production to recycling and waste management.

With stricter EPR requirements, including eco-modulation and packaging information requirements, how could these changes impact your role and operations as a converter?

At Avery Dennison, we understand that choosing the right label is important. Label choice can affect how packaging is assessed under EPR schemes, including recyclability-related fee modulation. In this article, we will guide you through key steps you can take to prepare your business and support brands as they respond to these regulatory changes. This can help you offer label solutions that support recyclability and may help customers manage EPR-related costs, depending on the complete packaging system and applicable market requirements.

Preparing for EPR fees

Although converters are not typically directly responsible for EPR fees for household packaging, it is important to prepare your business and customers for the regulatory changes ahead. Brands are likely to increase demand for label materials that support their packaging goals, including recyclability, reduced material use or recycled content where appropriate. They will also rely on converters to provide technical information that helps them assess packaging against evolving design-for-recycling guidance.

While the PPWR aims to bring more consistency to EPR schemes, understanding the connection between ecodesign principles and EPR fees is key to knowing which solutions may be most relevant for your customers.

The ecodesign approach

Ecodesign is an approach to product design that considers environmental impacts across the product lifecycle. For packaging, ecodesign principles can include reducing unnecessary material use, choosing materials compatible with relevant recycling streams, designing for reuse where appropriate and using compostable or biodegradable materials only where these options are suitable for the intended application and end-of-life route.

EPR Fees: What converters need to know and how to prepare

EPR schemes can use eco-modulation to adjust fees based on packaging characteristics such as recyclability performance, material composition or recycled content. Packaging that performs better against defined criteria may be eligible for lower fees, while packaging that is harder to collect, sort or recycle may face higher fees.

Ecodesign can therefore play an important role in EPR planning. However, fee outcomes depend on the full packaging system, the country where the packaging is placed on the market, the applicable producer responsibility organization and the criteria in force at the time.

How can you prepare your business and support brands for the impact of EPR fees on household packaging?

Understand and explain EPR regulations:
Research EPR regulations in the countries and markets where your brand customers operate. Identify the types of household packaging covered, fee structures, reporting requirements and timelines for compliance. Different markets may apply different EPR or eco-modulation fees. Understanding these differences will help you advise brands on label choices that support their packaging requirements. For example, in the Netherlands, the national EPR scheme includes fees based on packaging type and material.
Offer solutions aligned with packaging substrates:
Proactively suggest and develop label solutions designed for specific packaging substrates and recycling streams. Converters who understand how label materials, adhesives and constructions interact with packaging substrates can better support customers as they respond to EPR requirements. Examples of Avery Dennison solutions include:
- AD RDX™, a label portfolio designed to reduce material use and support applications across selected substrates, including HDPE, PP and cardboard
- AD CleanFlake™ adhesive technology, which is designed to support recycling of PET and HDPE packaging when used in compatible packaging systems
- Our rRange portfolio, which includes materials made with post-consumer recycled content or renewable materials from agricultural byproducts

Support compliance and reporting:
EPR compliance requires tracking and reporting on the types and quantities of packaging placed on the market. Inform your customers that they are generally responsible for EPR obligations related to packaging, including labels, and for providing required documentation to the relevant authorities or producer responsibility organizations. As a converter, you may need to provide supporting evidence, such as technical data sheets or material information, to help customers with accurate reporting and fee calculation.
Stay informed and communicate:
You can play an important role in helping customers navigate the complexity of EPR fees for household packaging. Engage with industry associations, local experts and other stakeholders to stay updated on EPR regulations, fee structures and design-for-recycling guidance. This will help you support customers with practical information on label choices, potential EPR fee impacts and strategies to improve packaging performance against relevant criteria. At the same time, recyclability and EPR considerations should be balanced with the performance requirements of the packaging application. Some formats, sizes and substrates may be more complex than others, so converters should seek technical support for trials, qualification and customer-specific assessments where needed.

By taking these steps, you can support customers as they prepare for evolving EPR requirements and contribute to packaging decisions that are better aligned with recyclability and circularity goals.

Our technical and sustainability specialists can help you make informed labeling decisions and assess how label choices may affect your customers’ packaging under PPWR and EPR requirements. They can also help identify label solutions that may support recyclability performance and EPR fee considerations, depending on the complete packaging system and applicable market criteria.

Learn more

Visit our PPWR page for more information on the legislation and its requirements.

Find more information on our labeling solutions for different packaging substrates. Discover our resources for PET, HDPE and PP, paper and cardboard and glass packaging or contact us for more information.

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EPR fees: what converters need to know and how to prepare