Eco-modulation in the EPR system in France – rules and obligations of manufacturers
On 1 January 2026, the regulations introducing eco-modulation of EPR fees came into force in France. Their aim is to popularize the use of recycled plastics while maintaining the high quality of the recyclate. The French government has decided to modulate fees in the bonus-malus system. In practice, this means that companies based on virgin plastic production will pay relatively more, and companies using recyclate will receive bonuses that will allow them to reduce the financial burden resulting from EPR.
The introduction of eco-modulation is also an important change for companies outside France. The EPR rules apply equally to both manufacturers and importers, cross-border sellers and online platforms. If you place products covered by extended producer responsibility regulations on the French market, then eco-modulation fees can significantly affect your company’s operations!
What is eco-modulation in the EPR system?
Eco-modulation is a financial mechanism that differentiates Extended Producer Responsibility (EPR) fees, taking into account the environmental impact of products and packaging placed on a given market. Ecomodulation may (but does not have to) be an integral part of the national EPR system.
It pursues two key objectives:
- increases the financial burden on manufacturers introducing less environmentally friendly products;
- reduces burdens or grants bonuses to those producers who use solutions more favourable to the circular economy.
In France, eco-modulation was introduced by the Regulation of 5 September 2025 laying down adjustments applicable to the financial contributions paid by producers when they use recycled plastic materials. According to these rules, the financial burden on manufacturers is modulated according to the recyclate content of selected products and packaging covered by the EPR. Unlike the solutions known from the PPWR regulation, the French model did not decide to apply differentiated fee rates – instead, producers who rely on circular economy receive financial bonuses in the amount proportional to the weight of the recyclate used.
What products are affected by the eco-modulation system in France?
According to the regulations in force from 2026, the French eco-modulation model does not cover all 22 product categories covered by the EPR regulations. Modulated fees have been introduced only for 8 selected product groups. These include:
- household packaging (including unit and multipack), printed paper (excluding books) and graphic paper;
- packaging intended for professional users (B2B),
- electrical and electronic equipment,
- selected chemicals and their packaging,
- furniture and textile elements of interior design,
- toys,
- sports and leisure goods,
- DIY products and gardening equipment and accessories.
Such a wide scope means that different product streams will be covered by eco-modulation in parallel, and modulated fees will be imposed, for example, on the product itself and its packaging. Companies introducing the above categories of products and packaging must therefore take into account an increased number of environmental obligations, and in the case of resignation from the use of recyclate – also an increase in EPR fees and a decrease in the competitiveness of their products.
Which companies are covered by eco-modulation in France? Subjective scope of the regulation
The eco-modulation system in France applies to the same entities that are subject to EPR obligations and introduce any products from the 8 categories mentioned above into France. Modulated EPR fees will therefore include:
- manufacturers,
- importers and intra-Community suppliers,
- companies selling products under their own brand (the so-called private label),
- in some cases, also distributors and resellers.
The rules of extended producer responsibility and eco-modulation in France are identical for all entities, regardless of the location of their headquarters. To cover a manufacturer with EPR regulations, it is sufficient to introduce the product to the French market. If you sell your goods to customers in France – also in the cross-border or e-commerce model – the eco-modulation regulations may also apply to your company.
Eco-modulation in the EPR in France – the basics of the bonus system
Under eco-modulation in France, manufacturers who introduce products covered by both EPR and eco-modulation can receive a financial bonus, the total amount of which depends on the amount of recycled plastics used. The bonus is calculated for each ton of recyclate actually used in products and packaging.
The regulation sets three different premium rates that a producer using recyclate can receive:
- 450 EUR/t – when the recyclate comes from the processing of post-consumer waste of products other than those in which it was reused,
- 550 EUR/t – when the recyclate comes from the processing of waste of the same category as the final product,
- 1000 EUR/t – if the recyclate was obtained from the processing of waste considered difficult to recycle. This group also includes recyclate intended for contact applications (e.g. food or cosmetic packaging). In the years 2026-2027, a reduced rate, i.e. 550 EUR/t, will be applied.
The bonus system is designed to encourage manufacturers to close material cycles within the same streams and to invest in technologies and installations for processing the most demanding plastics.
The premiums paid to producers are fully financed by EPR fees paid by producers. The obligation to account for them and administer the bonus system rests with the eco-organisations responsible for fulfilling the obligations of producers in relation to a given stream of products covered by the EPR.
In the future, the amount of the bonus may change – French producer responsibility organizations (éco-organismes, eco-organizations) can jointly propose a modification of the bonus amounts, while maintaining a special, formal procedure provided for in separate regulations.
How are eco-modulation bonuses granted?
The basis for granting eco-modulation bonuses is the amount of recycled plastics used to produce products and packaging of a given manufacturer. According to French regulations, bonuses:
- are charged for each tonne of recyclate used,
- are counted separately for individual types of plastics,
- They do not depend on the total weight of the product, but on the weight of the recyclate present in its composition.
However, the Regulation provides for a number of exemptions that limit the scope of the rules.
No bonus for meeting only the statutory minimum
For most categories of products covered by ecomodulation, there is no minimum level of recyclate, on which a premium is calculated. This means that even a small amount of recycled material present in selected products entitles the manufacturer to receive a bonus. However, there are exceptions to this rule – these include beverage bottles, for which minimum recyclate content thresholds have been established:
- bottles made of transparent, coloured and opaque PET – 25% recyclate until 31 December 2029 and 30% recyclate from 1 January 2030,
- HDPE bottles – 0% recyclate until 31 December 2029 and 30% recyclate from 1 January 2030
In the case of these packaging, the eco-modulation premium is only available for the weight of the recyclate exceeding the above minimums.
By setting minimum percentage thresholds for recyclate content in PET bottles, France has aligned its legislation with the SUP Directive (SUP). Single-Use Plastics, Directive (EU) 2019/904 of the European Parliament and of the Council of 5 June 2019 on the reduction of the impact of certain plastic products on the environment).
Bonuses only for locally produced high-quality recyclate
Applications of recyclate that would be contrary to the objectives of the introduction of eco-modulation in France have also been excluded from the possibility of receiving a financial rebate. This is to shift the market towards the actual use of recyclates, while eliminating any apparent solutions.
The weight of recyclate for which producers receive financial bonuses does not include:
- recyclate used in products containing composites that are difficult to recycle,
- recyclate containing materials or additives that interfere with the recycling process,
- recyclate from food packaging and chemical packaging containing processed PVC,
- recyclate from low-efficiency recycling processes.
In practice, this means that when calculating financial bonuses, not only the quantity, but also the quality of the recyclate used and the possibilities of reprocessing and using it in accordance with the idea of a circular economy are taken into account.
One of the key conditions for obtaining the bonus is also the fulfillment of the so-called proximity rule. It assumes that all stages of processing and use of recyclate (waste collection, sorting, recycling and incorporation of the raw material into a new product) must take place in a relatively close geographical area, including France and the European Union (or third countries with comparable environmental standards). If these conditions are not met, the manufacturer will not be entitled to receive a financial bonus.
The aim of these regulations is to reduce the transport of waste over long distances, promote real, regional recycling, eliminate sham activities and increase the transparency of supply chains. For companies with global value chains, this can be one of the most demanding elements of the system.
Eco-organizations are the pillars of the French eco-modulation system in the EPR
By virtue of the regulation of 5 September 2025, the entire administration of the eco-modulation system and the implementation of the obligations related to the granting and settlement of bonuses were entrusted to eco-organisations operating in the French EPR system. Their task will be, m.in, to calculate bonuses based on the data provided by producers, to create systems for verifying the data obtained, and to formulate requirements for the possibility of verifying the origin of recyclate used by producers.
Manufacturers using recyclate, on the other hand, are obliged to:
- indicate the content of recyclate in their products, broken down by individual types of plastics,
- documenting the origin of the material to be recycled (it must come only from post-consumer waste),
- demonstrate the high efficiency of the recycling process from which the recyclate was obtained,
- proof of compliance with the principle of proximity,
- confirmation of the absence of substances interfering with the recycling process.
Eco-organisations may also require producers to self-monitor, i.e. carry out internal audits, verify certificates or use other forms of control.
Eco-modulation in practice – how will the bonus-malus system affect your company?
For manufacturers, including foreign companies launching EPR products on the French market, eco-modulation means that:
- EPR fees cease to be a fixed cost. Thanks to eco-modulation, they can be optimized – they become dependent on the company’s commitment to the circularity of its products and packaging,
- decisions related to the design and selection of materials have a direct impact on financial burdens,
- to optimize EPR costs, it is necessary to cooperate with reliable recyclate suppliers with easy-to-trace value chains,
- The use of eco-modulation bonuses requires the involvement of not only the compliance department, but also purchasing, R&D and logistics.