Modulated EPR Fee for paper packaging

For the paper supply chain, the modulation project initially focused on applying an additional fee (EPR Fee supplement) for paper-based composite packaging suitable for containing liquids (“CPL”), in order to improve the effectiveness of the recovery process of more complex cellulosic packaging through consolidation and development of collection, sorting and recycling activities.

CONAI then extended this fee modulation to other types of composite or multi‑layer packaging predominantly made of paper or cardboard (other than CPL), again through an EPR Fee supplement, to align the EPR Fee with their actual recyclability, environmental impacts, and emerging end‑of‑life costs.

From 1 July 2025, there would be eight fee bands, with a twofold objective:

• strengthen the process of EPR Fee modulation, taking into account the industrial costs required to support recycling of packaging by introducing additional EPR Fee supplements (beyond the initial CPL supplement);
• recognise recyclability certification adopted by companies, applying a significant reduction for type B and type C composite packaging (other than CPL), whose recyclability level is determined according to the Aticelca 501 system*.

* This is a voluntary method of assessing recyclability based on a laboratory analysis carried out in accordance with the UNI 11743:2019 standard, which simulates the stages of the industrial process of processing paper for recycling and analyses the main elements that determine the recyclability of paper and cardboard products.

From 1 October 2025, the base EPR Fee for paper was reduced from €65.00/t to €45.00/t.

The new base EPR Fee values and the EPR Fee supplements, including the incentive for certified B1 and C1 composites, are as follows:

The expansion of the fee modulation project includes a one-year trial period and an initial assessment of the results and economics after six months. Operational Guidelines have been prepared to support companies in applying the new criteria correctly.

A sample form template of the declaration is also available for Users to send to Producers/traders to request the correct fee‑band allocation  (download the form template and completion instructions).

For further details, see the press releases of December 2024 and June 2025, and click here for the historical timeline page.