Paper modulated fee

Fee modulation for paper and cardboard packaging

Goal

Fee modulation is one of the levers used to guide companies toward increasingly recyclable packaging.

For the paper and cardboard supply chain, the modulation project has been aimed, starting with the application of an additional fee (EPR fee supplement) related to mainly paper-based polylaminates suitable for containing liquids (CPL), at improving the effectiveness of the value creation process of cellulose-based packaging that is more complex to recycle, through the consolidation and development of collection, sorting and recycling activities.

CONAI then continued with the fee modulation process for other mainly paper or cardboard based composite – or polylaminated – packaging types (other than CPL) – always through the application of an EPR fee supplement– in order to correlate the fee to their actual recyclability and environmental impacts, as well as the emerging costs associated with their end-of-life management.

New developments for 2025 (update following the Conai Board of Directors’ resolution of 27 November 2024)

The fee modulation project for paper and cardboard packaging has been expanded and, at the same time, important fee reductions have been brought in for non-liquid use composite packaging that has undergone a laboratory test conducted according to UNI 11743:2019 for which the level of recyclability has been assessed according to the Aticelca® 501 system.

* This is a voluntary recyclability assessment method based on laboratory test undergone according to UNI 11743:2019 which simulates the industrial working process of the paper needing recycling and analyses the main elements determining the recyclability of paper and cardboard products.

Starting from 1 July 2025, there will be eight fee bands for paper and cardboard packaging.

The first band remains specific to single-material packaging, and the second to type-A composites whose paper component is 90-95% of the overall weight of the packaging.

The B-type composite band in which the weight of the paper component is 80-90% of packaging weight, which was previously exempt from fees, was split into two. One of these will be dedicated to Aticelca® 501-certified B composites (B1) while the other to non-certified ones (B2). At the end of a first experimentation phase adjustments may be made to the Extra EPR fee values for B-type composites.

A further band remains specific to CPL.

The C-type composite band, with a 60-80% paper component, is also being split into two: Aticelca® 501 C certified as C1 and non-certified packaging as C2.

Lastly, a final band remains specific to D-type composites whose paper component is less than 60% of overall packaging weight or unspecified.

The new Extra EPR fee values with reductions specific to certified B1 and C1 composites are the following:

An experimentation period of one year is foreseen for the extension of the modulation project as well as an initial results and economics assessment phase after six months.

CONAI and Comieco guidelines for the correct application of the new criteria by companies will be coming out shortly and these will potentially include exemptions for firms issuing minimal volumes of composite packaging onto the market.

For further details regarding the rationale behind the increase in the basic fee, please refer to the Press Release December 2024, distributed to representative associations of packaging manufacturers and users as well as the consortium members involved.

Brief history

2018

Starting from 1 January 2018, CONAI introduced the modulated EPR fee for plastic packaging with the aim of encouraging the use of the most recyclable types and using the fee lever as a tool to promote the reduction of its environmental impact. In the past, some incentivised procedures were introduced for reusable packaging in controlled and particularly virtuous circuits from the environmental point of view.

In July 2018, the CONAI Board of Directors considered it appropriate to take a step forward – with a view to continuous improvement – and thus approved a fee modulation project for paper and cardboard packaging dedicated in the first instance to mainly paper-based polylaminated packaging suitable for containing liquids (CPL), for which industrial processes have been introduced in specialised paper mills since a number of years now for greater value creation in terms of recycling. In particular, this refers to primary packaging mainly in paper, coupled with plastic and possibly aluminium material. This item includes, by way of example, so-called beverage cartons (for milk, fruit juices, etc.) and the same types of packaging for other foodstuffs (sauces, purées, legumes, etc.). Packaging items for catering (plates, cups, containers with their lids) are, on the other hand, excluded.

From the activities carried out to date, it emerges that the best results in terms of recycling are obtained when polylaminated packaging mainly made of paper suitable for containing liquids is disposed of by citizens in light multi-material separate collection or in paper and cardboard separate collection and then sent to specialised paper mills for specific recycling.

The modulation project is therefore oriented towards the development of collection and remuneration of activities and investments for sorting and recycling operations, through the application of an EPR fee supplement on the specific type of packaging identified.

A dedicated Working Group of CONAI directors, belonging to the category of both packaging users as well as producers, was therefore set up for the necessary in-depth analysis which led to defining an EPR fee supplement of €20/t.

2019

Given an EPR fee for paper and cardboard packaging of €20.00/t, from 1 January 2019 an EPR fee supplement on polylaminates suitable for containing liquids of €20.00/t, for a total amount of €40.00/t was also applied.

More info

A summary of the process followed (validated by DNV GL, the certification body) can be found in the PAPER AND CARDBOARD modulated EPR fee summary document

The validation report (Paper and Cardboard Fee Validation_Report), on the other hand, is available in the Download documents, Publications and notes section.

At the same time, the COMIECO Consortium has undertaken to report on the results, after one year of experimentation and to provide – on request – more specific information.

2020 

A – (update following the Conai Board meeting of 17 July 2019)

As a result of the increase in the unit fee for paper and cardboard packaging to €35/t, as of 1.1.2020, application of the extra fee (confirmed at €20/t) has brought the EPR fee for mainly paper-based polylaminated packaging suitable for containing liquids to €55/t.

B – (update following the Conai Board meeting of 19 February 2020)

As a result of the increase in the unit fee for paper and cardboard packaging to €55/t, as of 1.6.2020, application of the  EPR fee supplement (confirmed at €20/t) has brought the EPR fee for mainly paper-based polylaminated packaging suitable for containing liquids to €75/t.

C – (update following the Conai Board meeting of 23 June 2020)

A year and a half after its entry into force, CONAI – at Comieco’s request – has decided to continue the process for other mainly paper-based polylaminated packaging other than CPL (packaging consisting structurally of two or more materials that cannot be separated manually, in which the main material in terms of weight is paper, and the weight of the non-cellulose material is, in any case, greater than 5% of the total weight of the packaging).

This modulation phase envisaged an experimental period of at least 12 months from October 2020 until December 2021, with specific forms, with the same EPR Fees, but with a clear distinction of the types of packaging subject to modulation. In fact, four new categories of mainly paper-based polylaminated packaging were envisaged based on the percentage by weight of the paper component:

• Type A polylaminates (Paper component ≥ 90% and < 95%), other than CPL
• Type B polylaminates (Paper component ≥ 80% and < 90%), other than CPL
• Type C polylaminates (Paper component ≥ 60% and < 80%), other than CPL
• Type D polylaminates (Paper component < 60%), other than CPL.

2021 (update following the Conai Board of Directors’ resolution of 19 May 2021)

Polylaminates for liquids

As a result of the reduction in the ordinary fee for paper and cardboard packaging (from €55.00/t to €25.00/t, from 1 July 2021), for paper-based polylaminated products suitable for containing liquids (CPL), the EPR fee was reduced – with the same starting date – from €75.00/t to €45.00/t, with the EPR fee supplement of €20/t remaining unchanged.

2022 (update following the Conai Board of Directors’ resolution of 19 May 2021, 14 October 2021 and 19 May 2022)

The Conai board of directors established the extension of the fee modulation also to other paper-based composite packaging other than containers for liquids and two decreases in the value of the EPR fee for paper and cardboard (from €25/ton to €10/t from 1 January 2022 and from €10/t to €5/t from 1 July 2022).

The new modulation came into force on 1 January 2022.

Mainly paper-based composite packaging, other than that for liquids, was divided into four types based on the weight of the paper component in the total packaging weight. In particular:

• for the first two types, A and B, with a paper component greater than or equal to 90% and 80%, respectively, no EPR fee supplement was applied for the time being;
• the third type, C, is that which qualifies packaging in which the paper component is greater than or equal to 60% and less than 80%. Recycling operations for such packaging are complex and costly: out of 100 kg of packaging, more than 60 kg becomes non-recyclable waste with current technologies;
• Starting from 1 January 2022, packaging in this band paid an EPR fee supplement of €110/t;

• the fourth type, D, is that of composite packaging in which the paper component is less than 60%: a percentage that compromises its recyclability to the point of nullifying it, with obvious environmental impact consequences. Indeed, in the recycling process, 100 kilograms of such packaging produces more than 85 kilograms of dry waste and nearly 150 kilograms of wet waste to be disposed of in landfills, after consuming water and electricity.
  For this packaging, the EPR fee supplement was therefore €240/t. Also included in Band D is packaging whose paper component is not specified.
  Therefore, since this packaging is not recyclable with paper and cardboard, the companies that produce and use it are asked to suggest on the label that it be disposed of with unseparated waste collection, in order to minimise the environmental impact linked to its end-of-life management.

EPR fee values for paper for 2022 were thus as follows:

• PAPER band 1 (base): €10/t (from 1/1) – €5/t (from 1/7)
• PAPER band 2 (CPL): €30/t (from 1/1) – €25/t (from 1/7)
• PAPER band 3 (type C composites) €120/t (from 1/1) – €115/t (from 1/7)
• PAPER band 4 (type D composites) €250/t (from 1/1) – €245/t (from 1/7)

 2023 (update following the Conai Board of Directors’ resolution of 12 July 2023)

From 1st October 2023 the paper and cardboard packaging EPR fee increased from €5/t to €35/t.

The remodulation of the EPR fee was due to a number of factors. Compared to forecasts for 2023, revenues from the sale of the material had decreased. The volumes of packaging put on the market and subject to the EPR fee also diminished primarily as a result of a contraction in industrial production in the main world economies as a result of well-known international events. All this has taken place against a backdrop of increased collection quantities.

COMIECO’s capital reserves were thus significantly below the desired threshold required to ensure continuity in collection and recycling commitments.

The values of the EPR fee supplements to be applied to paper-based polylaminated packaging suitable for containing liquids, to type C packaging (with a cellulose component greater than or equal to 60% and less than 80%) and to type D packaging (with a cellulose component less than 60% or not made explicit) have remained unchanged.

EPR fee values for paper for 2023 were thus as follows:

• PAPER band 1 (base): €5/t – €35/t (from 1/10)
• PAPER band 2 (CPL): €25/t – €55/t (from 1/10)
• PAPER band 3 (type C composites) €115/t – €145/t (from 1/10)
• PAPER band 4 (type D composites) €245/t – €275/t (from 1/10)

2024 (update following the Conai Board of Directors’ resolution of 18 December 2023)

The economic situation had led to an increase in the value of the base fee for paper and cardboard packaging which, from 1 April 2024, went from €35 /t to €65/t.

Following the reduction to 5 euros/tonne, in effect from June 2022 to October 2023, when the extraordinary values of pulp had made this downward revision possible, the main factors justifying the increase were: reduction beyond expectations, which began in the autumn of 2022, in the market values of pulp; increase in the quantities of packaging waste managed by COMIECO, despite the contraction in the quantities put on the market recorded in 2023; and the need to restore the Consortium’s capital reserves to a band suitable for ensuring continuity in collection and recycling commitments. Indeed, these reserves, due to the decrease in the EPR fee mentioned above, were gradually reduced by more than 150 million euros between the second half of 2021 and 2023.

On the other hand, there was no change to the values of the EPR fee supplements to be applied to paper-based polylaminated packaging suitable for containing liquids (€20/t), to type C packaging (with a cellulose component greater than or equal to 60% and less than 80%, equal to €110/t) and to type D packaging (with a cellulose component less than 60% or not specified , equal to €240/t). An assessment in this regard was planned during 2024, effective in 2025.

EPR fee values for paper are thus as follows:

• PAPER band 1 (base): €35/t – €65/t (from 1/4)
• PAPER band 2 (CPL): €55/t – €85/t (from 1/4)
• PAPER band 3 (type C composite) €145/t – €175/t (from 1/4)
• PAPER band 4 (type D composite) €275/t – €305/t (from 1/4)

Forms

All the information concerning the declaration forms is available in the “Conai Guide”, published annually, notwithstanding the support of the toll-free number 800337799.

Who to contact for clarification

In the FAQ section – Frequently Asked Questions (FAQ) – dedicated to the issue of “Fee Modulation” for paper and cardboard packaging, clarification is available on the main questions raised by companies and associations.

For any clarification or questions, in addition to the Toll-Free Number 800337799, an online form is available in the “Contacts” area, by selecting “PAPER and CARDBOARD Modulated Fee”.