EPR Fees on Metal Packaging 2026: Country-by-Country

Extended Producer Responsibility (EPR) fees for packaging in the EU are entering their most consequential restructuring in a decade. The Packaging and Packaging Waste Regulation (PPWR), generally applicable from 12 August 2026, introduces a harmonised recyclability-grade architecture (Grades A, B, C) that member states will use as the basis for eco-modulating EPR fees. The PPWR-aligned eco-modulation is mandatory from July 2029, with member states transitioning their schemes through 2026–2028. The market-wide expectation is that EPR fees across the EU will rise by 30–60% between 2027 and 2030.

For food producers using metal cans, easy-open ends and tinplate substrates, the picture is structurally favourable on the recyclability axis — steel packaging in the EU has been recycling above 80% for years, and aluminum substantially above the typical Grade B threshold — but operationally complex on the country-by-country axis. Member states retain the right to set actual fee levels and additional modulation factors, so a single EU-wide answer does not exist. Procurement reviewing 2026–2027 budgets needs a country-by-country view.

This article is that view, written for procurement, sustainability and finance leadership preparing Q3 2026 supplier reviews and 2027 budgets. It does not aim to summarise every member-state EPR scheme exhaustively; it aims to highlight where money is moving, what data to extract from suppliers, and how to translate the new PPWR architecture into supplier-contract language.

What PPWR’s eco-modulation framework actually changes

PPWR introduces three formal recyclability performance grades that EPR schemes will align with:

Grade A — at least 95% recyclability by weight.
Grade B — at least 80% recyclability by weight.
Grade C — at least 70% recyclability by weight.

Packaging falling below Grade C will be considered not recyclable and faces progressive market access restrictions from 2030. The recyclability assessment methodology — the harmonised “Design for Recycling” criteria — is to be set in delegated acts adopted by the European Commission by 1 January 2028.

Member states are required to modulate EPR fees by recyclability grade. Higher-grade packaging pays lower fees; lower-grade packaging pays higher fees, with the cost differential widening through 2027–2029. The mandatory alignment of national EPR fee schedules with the PPWR grade architecture becomes effective from July 2029 after the harmonised methodology and a transition period. In practice, member states are tightening their existing eco-modulation schemes in 2026–2028 in anticipation, so the fee curve is moving now — not at the 2029 gate.

PPWR is the harmonising layer. The fee levels remain national. Germany’s LUCID, France’s Citeo, Italy’s CONAI, Spain’s Ecoembes and equivalents in each member state continue to publish their own contribution rates, modulation factors and reporting requirements. Procurement needs to read each one.

Where metal food packaging structurally sits

Before walking through country specifics: metal food packaging is structurally well-positioned in the PPWR grade architecture. Steel and aluminum are infinitely recyclable in principle; the EU achieves high actual recycling rates on metal packaging (industry data from Metal Packaging Europe shows steel packaging recycling above 80% in recent years). For most assembled-can constructions with current coating and labelling systems, Grade B or Grade A is well within structural reach once the delegated acts on the recyclability assessment methodology are adopted.

The qualifier is documentation. A supplier who cannot evidence the recyclability grade for the specific format supplied — coating system included — leaves procurement exposed to the higher-fee tier by default. Eco-modulation rewards documented recyclability, not theoretical recyclability of the substrate.

The procurement question is therefore not “Will we benefit from the eco-modulation curve?” — most metal-can buyers will. It is “Will our supplier be able to document the grade for the specific format we purchase, in time for the 2027 fee invoice cycle?”

Germany — LUCID, ZSVR, and the transition from VerpackG to VerpackDG

Germany’s packaging law is in transition. The existing Verpackungsgesetz (VerpackG) is being replaced by the Verpackungsgesetz-Durchführungsgesetz (VerpackDG) to align national law with the PPWR. The Zentrale Stelle Verpackungsregister (ZSVR) — the central register authority — receives expanded competences under the new framework.

The LUCID Packaging Register continues as the central database for producer registration and data submission. Companies entering data must report material flows separately, including metal, to three decimal places. Reporting on 2025–2026 sales data is processed for invoicing in early 2027 — meaning eco-modulation outcomes from current operational decisions show up in cash a year later.

The fee architecture under the transitional German framework:

Grade A and Grade B packaging receive reduced fees relative to the un-modulated baseline.
Sub-Grade-C packaging — packaging that falls below the 70% recyclability threshold under the PPWR architecture — faces surcharges.
The dual-system operators (e.g., Der Grüne Punkt, Interseroh+, Reclay, Zentek and the others) set the per-system fee for each material, with the modulation overlay applied on top.

For metal packaging specifically, the per-tonne EPR contribution remains lower than for plastics (reflecting the higher recyclability) but is moving with the broader curve. Procurement buying for the German market in 2026 should:

Confirm that the supplier provides per-format recyclability documentation that the producer’s LUCID filing can rely on.
Understand which dual-system operator is contracted (this affects the base fee).
Hold a current declaration of recyclability methodology — ideally cross-referenced to RecyClass or a CEN standard.

France — Citeo’s bonus-malus architecture

France runs the longest-established eco-modulation system in Europe. Citeo, the PRO managing household packaging EPR, applies a bonus-malus mechanism layered on top of base material contributions.

For the 2026 fee schedule, the principal facts:

Aluminium base contribution: approximately 0.432 €/kg under Citeo’s 2026 household-packaging barème. Citeo administers the household packaging EPR scheme in France; the per-kg base contribution is materially higher than the per-tonne industrial-packaging contributions in other member states, so cross-country comparisons must account for the scope difference (household-only French scheme versus broader scope in Germany, Italy and elsewhere). Steel contribution is at a lower level reflecting the higher recyclability and recovery economics of tinplate-based packaging.
New 2026 bonuses: a 5% reuse bonus on the total contribution for certified reusable packaging, and a recycled-content bonus proportional to the incorporation rate — up to a 15% contribution reduction for packaging containing 80% recycled material.
Malus structure: maluses (surcharges) are introduced stepwise — typically 10% in the first year, escalating to 50% within one to three years, and reaching 100% within two to five years, depending on the trajectory set by Citeo for each non-compliance category.

For context on order of magnitude: in 2023, Citeo applied bonuses and maluses across roughly 750,000 tonnes of covered packaging, resulting in approximately €24 million in bonuses paid out and €9.8 million in maluses collected. The 2026 schedule expands the categories under modulation.

For procurement buying for the French market, the operational implications:

Recycled-content data on substrate becomes a direct EPR-fee input. The substrate-origin disclosure exercise that satisfies CBAM transparency feeds Citeo bonus eligibility.
Recyclability documentation must align with the Citeo eco-modulation criteria and the underlying RecyClass / CEN methodologies.
The bonus-malus mechanism rewards proactive supplier alignment — and penalises drift.

The Citeo 2026 tariff schedule is published openly; procurement should treat it as a reference document for budget reviews, not as background reading.

Italy — CONAI and the material-specific consortia

Italy runs a unified national packaging EPR system administered by CONAI (Consorzio Nazionale Imballaggi), with material-specific recycling consortia handling the operational fund flow: RICREA for steel, CIAL for aluminum, COREVE for glass, COMIECO for paper, CORIPET / COREPLA for plastics, and RILEGNO for wood.

Current CONAI Environmental Contribution rates relevant to metal packaging:

Steel: 5.00 €/tonne of packaging placed on the market.
Aluminum: 15.00 €/tonne (in effect since 1 January 2019).

For 2026, CONAI has scheduled rate increases primarily for glass and wood packaging; the metal-can rates have not been publicly announced as changing at the same step. Plastic rates are reviewed quarterly. Procurement buying for the Italian market should:

Confirm the current per-tonne rate for the format purchased (steel vs aluminum, can vs EOE distinction not material at the CONAI rate level).
Understand that PPWR-aligned eco-modulation is being layered onto the CONAI architecture — the existing rate is the baseline, with modulation overlay coming.
Hold a current declaration of recyclability for cross-referencing with the consortium-level reporting.

CIAL and RICREA both publish technical guidance on the eco-modulation criteria they apply for member packaging.

Spain — Ecoembes, the single-PRO transition, and the Royal Decree framework

Spain’s EPR system is in transition from the historic Ecoembes-only PRO model to a multi-PRO competitive landscape under the framework of Royal Decree 1055/2022 on packaging and packaging waste, published in the official state gazette (BOE) at the end of 2022. The new framework aligns with PPWR direction.

For 2026, the operational situation:

Ecoembes continues to administer the largest share of household packaging EPR for metal cans, with Ecoembes’ tariff schedule published annually.
Multiple PROs are now licensed to operate; producers can choose, with associated rate variation.
Eco-modulation is in effect and tightening progressively in line with the PPWR direction.

Procurement buying for the Spanish market should clarify which PRO covers the producer’s obligation and reference that PRO’s specific 2026 tariff. The fee differentials between PROs can be material.

Poland and CEE — the harmonisation gap

Poland’s EPR for packaging is moving from a historically loose framework toward a tighter PRO-administered system under EU pressure. The Ustawa o rozszerzonej odpowiedzialności producenta (ROP) legislation, in implementation phases through 2025–2027, is the vehicle.

For procurement buying for the Polish market in 2026:

The previous low-fee environment is changing; expect material fee increases through 2027.
The eco-modulation architecture aligned with PPWR is in legislation but operationally still settling.
Supplier documentation requirements are moving toward EU norms but with Polish-language reporting standards.

Similar situations apply across CEE — Czechia, Slovakia, Hungary, Romania, Bulgaria — with each at different points in PPWR implementation. The transitional regulatory window in 2026 means procurement should not assume CEE-wide low-fee status for the next 12 months.

The procurement-side implications

Across all member states, three patterns hold.

First, the absolute fee number per tonne of metal packaging remains far below the equivalent for plastics, glass and multi-material formats. Steel and aluminum eco-modulate favourably under PPWR’s grade architecture, and the contribution rates reflect this. A food producer using metal cans is structurally on the right side of the EPR fee curve relative to the alternatives.

Second, the documentation requirements for capturing favourable eco-modulation rise sharply. The grade-based fee scheme requires per-format recyclability evidence. A supplier who cannot provide that evidence leaves the producer paying the higher un-modulated tier. The documentation overlap with PPWR compliance, CBAM substrate-origin disclosure and CSRD scope-3 reporting is substantial — one supplier conversation, run properly, satisfies all four.

Third, the per-country variation is material and growing. Procurement managing multi-market portfolios needs per-country tariff visibility on its supplier base, not an EU-average assumption. The fee differential between Germany, France, Italy, Spain and the CEE markets is real money on a multi-SKU portfolio.

Seven questions to ask every metal packaging supplier before 30 September

What recyclability grade can you document for the can / EOE / tinplate format we purchase, by which methodology — RecyClass, CEN, member-state framework — and dated when?
What recycled-content percentage does the substrate carry, in which data year, and from which mill source?
For the German market, does the format meet ZSVR / VerpackDG documentation standards for LUCID reporting?
For the French market, can you confirm the format’s Citeo bonus-malus position — recycled-content bonus eligibility, any malus exposure?
For the Italian market, can you confirm the current CONAI material classification — RICREA (steel) or CIAL (aluminum) — and the current per-tonne contribution rate applied to the format?
For multi-market portfolios, can you provide a per-country EPR documentation summary that procurement can hand to finance for 2027 fee budgeting?
What is the methodology by which you maintain currency of recyclability and recycled-content data — refresh cadence, named owner, audit trail?

Suppliers operating to a mature standard answer all seven in writing with current data. Suppliers operating below that standard leave the producer with the higher fee tier and a Q4 audit gap simultaneously.

Cross-references — one supplier conversation covers four reporting demands

The supplier-disclosure exercise this article describes overlaps meaningfully with three other supplier-data demands hitting procurement in the same window.

PPWR (Regulation (EU) 2025/40) applies from 12 August 2026 and is the harmonising framework for the EPR eco-modulation grades discussed here.
CBAM (Regulation (EU) 2023/956), in its definitive period since 1 January 2026, requires substrate-origin disclosure — the same data point that anchors recycled-content statements for EPR bonus eligibility.
CSRD reporting for in-scope companies requires scope-3 supplier-level data, including recycled content, that overlaps with EPR documentation.

A procurement team that runs a single, structured supplier disclosure exercise this quarter — covering format, substrate origin, recyclability grade, recycled-content percentage, coating compliance and CBAM cost component — gets the documentation foundation for all four supplier-data demands in one conversation rather than four.

Action plan for Q3 — week by week

Weeks 1–2 (early to mid-June): Inventory the supplier base by markets served. Build a per-country EPR exposure map covering Germany, France, Italy, Spain, Poland and the smaller markets in the portfolio.

Weeks 3–4 (mid-to-late June): Send a structured documentation request to every supplier, covering the seven questions above, with a response deadline of 24 July. Use a single common template — the same one used for PPWR, CBAM and bisphenol documentation.

Weeks 5–8 (July): Map responses against the per-country eco-modulation requirements. Identify where the format qualifies for bonuses (recycled content, recyclability grade) and where it sits in the standard or un-modulated tier. Escalate gaps to suppliers’ commercial leads with a 14-day deadline.

Weeks 9–11 (August): For SKUs exposed to material fee escalation in 2027, initiate second-source sampling against suppliers with stronger eco-modulation positions. Cross-reference QA documentation against the PPWR and bisphenol work running in parallel.

Weeks 12–13 (early September): Q3 supplier review with finance and sustainability leadership. Present the per-country EPR exposure map, the documentation gaps closed, the second-source qualification status, and the projected 2027 fee impact by SKU and market.

What this does not cover — and where the conversation goes next

EPR fees are not the only line item moving through 2026–2030 in the packaging cost stack. CBAM is restructuring substrate-cost economics. ETS2 (now applying from 1 January 2028 following the March 2026 postponement) and the maritime extension of EU ETS are restructuring logistics-cost economics. CSRD chemical-disclosure expectations are tightening. The bisphenol regulatory regime under Regulation (EU) 2024/3190 is in mid-transition.

A procurement team that builds a clean supplier-contract framework for EPR fee modulation also positions itself well for those adjacent conversations. The supplier-disclosure discipline that handles eco-modulation evidence applies equally to CSRD scope-3, CBAM passthrough and bisphenol compliance.

Q3 2026 is the window. The fee architecture set up now governs how the next twelve months of packaging EPR cost behaves across multiple member-state schemes — and where the procurement team has visibility versus where it does not.

Sources and primary references

This article is general procurement guidance. It is not legal, tax or compliance advice. Specific EPR fee calculations, country-by-country registration obligations and supplier-contract decisions should be reviewed with EPR compliance and tax advisors familiar with each market’s scheme rules and your operational footprint.