Eco-modulation
The easier your packaging is to recycle, the lower your contribution. Here you can see which materials are eco-modulated, what the level means for the price, and how you eco-modulate.
The easier to recycle, the lower the contribution
Every material has a base rate per kg. On top of that comes an eco-modulation based on how easy the packaging is to recycle. If it is easy (green), you pay less. If it is hard (red), the contribution goes up. The point is to reward packaging that is designed to be recycled.
You must eco-modulate from 8 tonnes per year. Below the threshold it is voluntary. See the de minimis threshold.
Three levels
Two levels
No eco-modulation
Which materials are eco-modulated, and how many levels?
Eco-modulation applies to 10 material sub-categories (Annex 14). Some are split into three levels (green, yellow and red), others into two (green and red). A number of materials are not eco-modulated at all and pay the base rate.
| Material | Eco-modulation |
|---|---|
| Flexible plastic | Green, yellow and red |
| Rigid plastic | Green, yellow and red |
| Foamed plastic | Green, yellow and red |
| Rigid PET | Green, yellow and red |
| Food and beverage cartons | Green, yellow and red |
| Glass | Green and red |
| Cardboard | Green and red |
| Paper | Green and red |
| Ferrous metals | Green and red |
| Aluminium | Green and red |
| Wood, ceramics, porcelain, cork, textile and other | No eco-modulation, base rate |
What does the level mean for the price?
Red packaging gets a malus of +35% on top of the material's base rate. The money from the malus is used as a bonus for green packaging in the same material. Green and yellow always pay at least 20% of the base rate, though.
In short, red is penalised and green is rewarded, within each individual material. You will find the actual rates on prices.
Green, bonus
Yellow, base rate
Red, +35%
What decides whether your packaging is green, yellow or red?
The design decides the level, not a general assessment. If just one criterion cannot be documented, the packaging is placed in red.
| Criterion | Pulls towards green or red |
|---|---|
| Material composition | Pure PP/PE pulls towards green. Mixed multi-layer materials, for example PET, PVC, PS and paper together, pull towards red. |
| Density | PE/PP at no more than 1 g/cm³ pulls towards green. Material above 1 g/cm³ pulls towards red. |
| Colour and sortability | Uncoloured or NIR-sortable pulls towards green. Carbon black or not NIR-sortable pulls towards red. |
| Barriers, adhesives and printing inks | Recycling-friendly ones pull towards green. If they hinder recycling, that pulls towards red. |
| Recycled content | A higher share pulls towards green. |
How you eco-modulate your packaging
Five steps, from splitting up the packaging to reporting the level. The hard part is rarely the assessment itself, but having the documentation ready.
How you get the documentation
Eco-modulation rests on documentation for every criterion, and you get that from your suppliers. Write to them and ask for specifications or technical documentation on the packaging, for example a data sheet describing material composition, colour, adhesives and barriers. Once you have the documentation together, your packaging does not end up in red just because a criterion has not been documented.
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1
Split up the packaging
The main component plus components that can be separated by ordinary handling, for example lids, labels and caps.
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2
Determine the material
Each component is categorised by its dominant material (by weight) into one of the 10 material sub-categories.
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3
Check against Annex 14
Assess each component against the design criteria for that specific category.
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4
Document every criterion
If documentation is missing for just one, the packaging goes into red.
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5
Document the level to us
Eco-modulation is not a field in the report to DPA. You document the level to us as your PRO, and that requires a detailed membership. See the de minimis threshold.
Shall we go through the documentation together?
If you have the documentation from your suppliers, we are happy to look through it and help work out whether your packaging lands in green, yellow or red. Book a call and we will take it from there.
