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For most of the last decade, Extended Producer Responsibility (EPR) was something brands tracked from a distance: a regulatory trend, mostly European, mostly future tense. That distance has closed. As Vela noted earlier this year, packaging is changing across every front brands need to watch, but EPR is where that change gets a price tag. Across the EU, the UK, and now a growing list of US states and Canadian provinces, 2026 is the year EPR shifts from policy to payment. Fees are being invoiced, registrations are due, and, critically, the amount a brand pays is increasingly determined by how recyclable its packaging actually is, not just how much of it there is.
Extended Producer Responsibility shifts the financial and operational responsibility for packaging waste from municipalities to the businesses that put packaging on the market. In practice, a stewardship organisation or Producer Responsibility Organisation (PRO) collects fees from producers based on weight and material type, and, in a growing number of schemes, on eco-modulation: bonuses for packaging designed to be recycled, and penalties for packaging that isn't. As Amcor's packaging guidance puts it plainly, most brands will be charged, and the fee "will become an integral part of the cost structure."
The mechanics vary by market, but the direction is consistent: flat, weight only fees are giving way to fees that reward mono material, widely recyclable, disruption free packaging, and penalise composite, hard to sort formats.
According to the EPR Trends Report 2026, published by compliance platform Recyda, 2026 is the year several major EU schemes move from simple weight based fees to detailed, design based ones:
Belgium (Fost Plus) raised its average plastic packaging rate by 9.61% for 2026, with EPS packaging fees up 110.5% and PE bottles up 55.7%, both increases directly tied to how difficult a format is to recycle.
Spain (Ecoembes) moved the opposite direction on average plastic rates, down 9.85%, rewarding packaging that meets two or more eco design attributes while applying a 10% penalty to non recyclable features, inseparable multilayers, and incompatible inks or glues.
Portugal introduced eco-modulation for the first time on 1 January 2026, applying a 10% bonus for design for recycling packaging and continuing a 10% penalty on disruptive components introduced in 2022.
Italy (CONAI) restructured plastic fees by recyclability tier between July 2025 and January 2026, with the hardest to recycle tier rising from €441/t to €611/t.
France introduced a dedicated B2B packaging EPR scheme from 1 January 2026 and a tiered recycled content premium of up to €1,000/t for difficult to recycle resins in contact sensitive packaging.
All of this sits underneath the EU's broader Packaging and Packaging Waste Regulation (PPWR), which is pushing member states toward harmonised recyclability standards by 2030. It's a shift Vela has covered in more depth in "From Regulation to Reality: The New Era of Packaging in Europe."
The UK's new packaging EPR scheme, run by PackUK, deliberately separated data reporting from cost. Fee payments began in late 2025. The consequential part, eco-modulation based on the Recyclability Assessment Methodology (RAM), starts landing on 2026/27 invoices. PackUK's confirmed framework applies escalating modulation factors of 1.2x in year one, 1.6x in year two, and 2x in year three to packaging rated "red" for recyclability, against illustrative base rates of roughly £415/t for green rated plastic and £545/t for red rated plastic. On a meaningful volume, that gap runs into the millions. The design window brands were given in 2025 to fix red rated formats is now closing.
The US has no federal EPR law, but 2026 is the year several state schemes move from legislation to enforcement. Circular Action Alliance (CAA), the producer led PRO now operating in California, Colorado, Maryland, Minnesota, Oregon and Washington, submitted California's SB 54 program plan in mid 2026, ahead of full financial obligations beginning January 2027. Oregon and Colorado moved into their first year of mandatory fee payments on 1 January 2026. Maryland's registration deadline lands 1 July 2026. Across the border, British Columbia, Nova Scotia, and New Brunswick all enter binding compliance phases this year, coordinated in part through the Circular Materials PRO network. Vela has looked at the sharpest edge of this shift, California's labelling and recyclability rules, in "Why apparel brands are rethinking plastic polybags in California."
The result, as the Recyda report notes, is a genuinely fragmented compliance map: a single SKU sold in California, Oregon, Ontario, and the Netherlands can face four different fee structures, four different reporting calendars, and four different definitions of what counts as "recyclable."
Across EPR schemes, fees are increasingly driven by packaging design, not just weight. Mono material, widely recyclable formats benefit from lower fees or eco-modulation bonuses, while multilayer and hard to recycle packaging costs more. Standards such as CEPI are also becoming key references for determining what qualifies as recyclable in practice.
For apparel and ecommerce brands still relying on plastic polybags as a packaging default, this changes the calculation. It's no longer purely a sustainability or brand perception decision. It's a cost line that compounds across every market a brand ships into. Paper based, fully recyclable formats sit structurally on the favourable side of most eco-modulation frameworks, because they're already circular by design: mono material, disruption free, and built for the recovery streams these schemes are engineered to reward. That's not just lower plastic exposure. It's lower exposure to the fee structures now being written around recyclability.
EPR is not converging toward a single global standard any time soon. The EU, UK, and North America are each writing their own rules, at their own pace, with their own definitions of recyclability. What is converging is the underlying incentive: packaging that performs within real recycling systems costs less, packaging that doesn't costs more, and that gap is only going to widen as more schemes mature into eco-modulation. Brands that treat their 2026 packaging spec as a one time compliance task will be revisiting it again in 2027 and 2028, at a higher price. To see how a shift to paper based packaging fits into that timeline, explore Vela's onboarding process.
Recyda: EPR Trends Report 2026
Amcor: How Extended Producer Responsibility Impacts My Packaging
European Commission: Packaging and Packaging Waste Regulation (PPWR)
OECD: Extended Producer Responsibility
Circular Action Alliance: About
Circular Action Alliance: California (SB 54)
Vela: From Regulation to Reality: The New Era of Packaging in Europe
Vela: Why Apparel Brands Are Rethinking Plastic Polybags in California
Vela: Packaging Is Changing. Is Your Brand Ready?
Vela: What Is the CEPI Recyclability Framework and Why It Matters
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