The use of plastic in packaging is associated with costs throughout Europe that do not apply to other packaging materials. From plastic taxes to EPR and license fees, special levies are incurred, but these vary from country to country and are also subject to different conditions. We take a look at the EU plus the UK for you and consider the status quo as well as the “PPWR future”: Where does the use of recycled material directly save money, where and when are license fees incurred, and where does the use of recycled material not reduce costs, or only do so very indirectly?
Plastic taxes: Where does the use of recycled material directly save money?
Some countries have already implemented a “plastic tax,” others have formulated it, and some are just beginning the political process. We look at the UK, Spain, Italy, Portugal, Ireland, Estonia, and the “basic EU plastic levy.”
UK – Plastic Packaging Tax (PPT)
- Mechanics: The PPT only applies to packaging that contains less than 30 percent recycled plastic. Anything ≥ 30 percent recycled material is completely exempt from the tax. (Source)
- Tax rate: As of 2025, the PPT is around £223.69 per ton of chargeable plastic (equivalent to around €255 at the end of November 2025). The fee rate is regularly adjusted to inflation rates. (Source)
- Threshold: From 30 percent recycled content, the PPT is completely waived. This means that the tax is then £0, regardless of whether 30 or 80 percent recycled content is used. There is no sliding scale.
- Consequence for the use of recycled material: Recycled material is particularly worthwhile financially as a “leap” over the 30 percent threshold. More recycled material above 30 percent does not bring any additional direct tax advantage in the PPT system, but can of course support other sustainability goals.
- Exceptions: The PPT does not apply to:
- medical packaging (e.g., clinical use)
- primarily non-functional plastic components (e.g., small parts, if <5 percent of the total weight),
- exported packaging,
- reusable transport packaging (with a clear reusable structure).
Spain – Tax on non-reusable plastic packaging
- Tax rate: €0.45/kg on non-recycled plastic in the packaging concerned. (Source)
- Tax base: Only the amount of non-recycled plastic is explicitly taxed. Recycled content in the packaging is not taxable if the recycled content is certified by an accredited body. (Source)
- Consequence: In purely mathematical terms, the following levies apply to 1 ton of non-recyclable plastic packaging:
- without recycled material → €0.45/kg × 1000 kg = €450,
- with 50% recycled material → €0.45/kg × 500 kg = €225,
- with 100% recycled material → €0
- Special features:
- The recycled content must be verified by accredited certificates.
- Recyclate in polymers and additives is eligible.
- Consequence for the use of recycled material: In Spain, each percentage point of additional recycled material leads to a linear reduction in the plastic tax, as long as the proportion is correctly certified.
- Exceptions:
- plastic content <5% of total packaging,
- medical and pharmaceutical packaging
- industrial reusable/transport packaging
- packaging that is exported or meets EU internal market-specific exemptions.
Italy – “Plastic Tax” on MACSI (planned from 2026)
- Status: The tax has already been postponed several times. It is currently scheduled to come into force on January 1, 2027. The law itself has already been drafted. (Source)
- Tax rate: €0.45/kg of non-recycled plastic in single-use plastic products (“MACSI”). (Source)
Portugal – Contribution on single-use plastic/aluminum packaging
- Mechanism and tax rate: A flat-rate levy of €0.30 per item is levied on single-use packaging units that consist entirely or partially of plastic or aluminum. (Source)
- Tax base: The levy is not linked to “non-recycled plastic” or recycled content, but to the presence of plastic or aluminum and the single-use nature of the packaging.
- Consequences for the use of recycled materials: The use of recycled materials does not directly reduce the fee. Only a switch to reusable packaging or materials not covered by the levy can avoid the charge.
France
- Status:
- The planned national plastic tax was rejected by the French Parliament at the end of November 2025. (Source)
- However, France will introduce a graduated fee structure as part of its EPR system for packaging: In the future, the amount of the EPR fee will depend on the composition, recyclability, and type of packaging — in other words, it will be eco-modulated. (Source)
- Eco-modulation will start on January 1, 2026.
- The aim of eco-modulation is to create incentives for recycling-friendly, sustainable packaging (e.g., monomaterial, high recycled content, good sortability and recyclability). Packaging that is difficult to recycle will be subject to higher charges.
- Consequence for the use of recycled materials: The use of recycled materials will be promoted if the entire process steps, from collection to sorting and recycling to use, take place within a radius of 1,500 km from the geographical center of France and within the EU.
- Commercial packaging: On November 17, the legal ordinance integrating commercial packaging into the existing EPR system was passed. Eco-modulated fees are also planned for this type of packaging. (Source)
Ireland – Planned tax (still under political discussion)
- Focus on behavioral change in the to-go sector, not on material types.
- PCR has no influence on the levy.
- Expected to be exempt:
- Reusable products
- Special hygiene or health applications
- EPR remains in place.
Estonia – Planned tax
- Based on the Spanish model:
- €0.40-0.50/kg of non-recycled plastic
- PCR to be fully creditable.
- Political discussion still open (as of the end of 2025).
- Exemptions (planned):
- medical packaging
- exports
- industrial reusable packaging
- very small quantities (de minimis limit)
EU “plastic tax” (EU own resource)
- At EU level, there is a levy of €0.80/kg on non-recycled plastic packaging waste, which must be paid by the member states to the EU and which increases the EU’s own resources. (Source)
- How individual EU countries “refinance” this levy is at their own discretion. For example, they can contribute the sum from their own budget or pass it on to companies (producers, distributors, etc.). The practice applied differs from one Member State to another.
- Indirect effect: More recycled material and better recycling rates in the country reduce the national levy in the long term, which motivates governments to introduce national taxes/levies on non-recycled plastic, as is the case in Spain, for example, and is planned in Italy.
EPR/license fees (“system fees”) and recycled material
- EPR fees are calculated differently in many cases in the individual EU member states and the UK and are often primarily linked to recyclability and material type.
- Recyclate has so far only been established as a direct fee factor in a few cases, but is set to become more important as a fee factor under the PPWR.
Today: Eco-modulation in Germany & Europe
- Under EPR, distributors pay license fees to systems/producer responsibility organizations (PROs). “Eco-modulated” fees, where the amount varies depending on the environmental performance of the packaging, are becoming increasingly common. (Source)
- Typical criteria for environmental performance include, for example:
- recyclability (mono-material, sortability, etc.)
- material type (paper vs. plastic, composites)
- partially recycled content
- reusability, freedom from harmful substances, etc.
Example: Germany today
- The VerpackG obligation to participate in the system is based on material and mass (plastic is more expensive than paper, etc.). (Source)
- Eco-fee modulation is based on the recyclability of the packaging. Those who use “good” designs receive reduced license fees. Surcharges must be paid for “bad” designs. (Source)
- In practice, some system providers already take the use of recycled material into account, either directly or indirectly. However, the main lever is currently design-for-recycling quality (e.g., monomaterial PE bags with standard colors vs. complex composites).
- The mechanism for eco-modulation has been formally valid in Germany since 2024, but:
- fee/tax rates still need to be specified by statutory order,
- the focus is on single-use plastic products (SUP implementation) and
- it is still unclear (although politically likely) whether the EU “plastic tax” will be implemented (and in what form).
- A flat-rate packaging tax as in Spain or Italy is not expected – instead, product group-specific taxes will be introduced.
Conclusion of the status quo “today”:
- Improving recyclability is a sure cost-cutting lever for EPR fees.
- The use of recycled material or the proportion of recycled material is sometimes rewarded additionally, but is not yet a uniform EU standard.
- Whether and to what extent recycled material reduces system fees depends on the respective system and country (bonus/penalty tables, discounts, etc.).
PPWR: Recyclate as an official modulation factor
The new Packaging and Packaging Waste Regulation (PPWR) is reshuffling the deck. It applies uniformly throughout the EU, with implementation starting in August 2026 and staggered transition periods. (source)
Among other things, the PPWR stipulates:
- Binding minimum recycled content for plastic packaging (10–35 percent by 2030, depending on the application; further increases by 2040). (Source)
- Eco-modulated EPR fees based on recyclability, which may explicitly use recycled content as an additional criterion for plastics (“Minimum recycled content in plastic packaging (…) can serve as a further criterion for modulating the EPR fees.”)
- In addition, the PPWR links recyclability to A–C grades and minimum requirements across Europe.
- Packaging with less than 70 percent recyclability will no longer be allowed on the market from 2030.
Consequences for fees:
- Short term (until approx. 2026/27):
- In many systems, recycled material is at most a “soft” modulation factor or does not yet play a direct role at all.
- The main cost effect is the choice of materials and design for recycling.
- Medium/long term (from 2027 onwards):
- Member states must modulate EPR fees and may explicitly take into account the recycled content of plastic packaging. (Source)
- Expected structure:
- High recyclability + high PCR content → low fees
- Poor recyclability + low PCR content → high fees or penalties
- Studies and advisory articles suggest potential savings of 20–50 percent of EPR costs with optimized, highly recyclable, and PCR-rich packaging. (Source)
UK EPR (PackUK) – modulated disposal fee
In addition to the Plastic Packaging Tax (PPT; see above), the UK is also introducing its own EPR system for packaging with a modulated fee.
- From Year 2 (2026), EPR disposal fees will be modulated based on a Recyclability Assessment Methodology (RAM) with traffic light classes (red/amber/green). (Sources)
- Modulation is primarily based on:
- the recyclability of the material and format,
- but not explicitly on the recycled content.
- The use of recycled material remains more of an indirect lever here (e.g., because highly recyclable, standardized formats tend to enable high PCR quotas).
Conclusion for the UK:
- PPT is a direct, hard recycled material lever (with a 30 percent threshold).
- The EPR fee is primarily based on recyclability. The use of PCR can help strategically, but is not yet an independent fee parameter.
Where does recycled material not result in any (or only very indirect) fee reductions?
In systems or levy regulations that charge flat fees per item or per kg regardless of recycled content, as is the case with Portugal’s disposable packaging levy, for example, the use of recycled material is not directly rewarded. (Source)
EPR systems, which currently only differentiate according to material type and mass and do not (yet) apply eco-modulated tariffs, do not currently offer any specific recycled material discounts either. Here, the use of recycled materials contributes at most to image and corporate social responsibility.
Summary
Where does the use of recycled materials already pay off directly and clearly today, where will it increase significantly in the medium term, and where does it pay off indirectly or not at all?
Directly and clearly (hard savings levers):
- UK PPT: ≥ 30 percent recycled material → £0 tax; below that, full rate.
- Spain Plastic Tax: Each ton of PCR reduces the tax by €0.45/kg (tax base = non-recycled plastic).
- Italy Plastic Tax (from 2026): Similar to Spain – tax only on non-recycled plastic (€0.45/kg); products made from recycled material are exempt from the tax.
Strong increase in the medium term:
- EU-wide via PPWR and EPR eco-modulation:
- The recycled content in plastic packaging is explicitly established as an additional modulation factor for EPR fees.
- Expected: significantly lower license fees for packaging with a high PCR content and high recyclability
Rather indirect or not (yet) at all:
- Portugal: Single-use packaging contribution and comparable unit charges. Here, recycled material has no influence on the contribution obligation.
- EPR systems with no or very rudimentary eco-modulation: Recyclate is rewarded voluntarily, if at all, but not systematically.
Overview table
