“In 2024, eco-modulation of fees for packaging companies in Spain will begin: thermoformed PET packaging may benefit from a discount”

The modulation of the financial contributions made by packaging companies to the collective systems of extended producer responsibility (EPR), commonly known as eco-modulation and which, for example, has been applied for years in countries such as France (CITEO), will already be a requirement mandatory in Spain from 2024 after the approval of Royal Decree 1055/2022 on packaging and packaging waste which, together with Law 7/2022, transposes Directive (EU) 2018/851, which includes the need to harmonize the operation of EPR systems in member countries.

In this sense,ECOEMBES has published an “Eco-modulation Guide” to inform their licensed companies how this new financial contribution model will be, implying a series of discounts and penalties when packaging meets or fails to meet certain ecodesign criteria. For the definition of this model, which, as the guide indicates, has been established in a transparent and non-discriminatory manner, guaranteeing the participation of all interested parties, it has been possible to take into account the criteria of Annex VIII of RD 1055/2022 or other similar ones that have been able to be applied, given that the aforementioned annex will not be binding until 4 years from its entry into force once the Ministry of Ecological Transition and Demographic Challenge has analysed the effects of this adopted modulation.

The technical and economic model that ECOEMBES follows for the eco-modulation of fees, and which is described in detail in this guide, has the fundamental objectives of promoting the incorporation of post-consumer recycled raw materials and increase the recyclability of collected packaging. To do this, it uses what it calls “technical attributes” which are 5 characteristics of the packaging that can cause the green dot base fee to obtain a discount, remain neutral or be penalized.

In the specific case of the PET tray, among other issues, the base fee will be subsidized with a 5,5% discount if the packaging contains more than 25% post-consumer recycled material* and will be penalized with a 10% increase in the base fee for coloured and opaque packaging (for more details, consult the guide on pages 23, 28, 29 and 38)::

* * In order to benefit from this discount, from the Foundation Ecosense we encourage packaging companies that place thermoformed PET packaging on the Spanish market to certify the recycled content in their products through the RETRAY certification that meets the requirements of the EN 15343 standard and operates under accreditation of the Certification Bodies for the standard ISO/IEC 17065.