Eco-modulation has emerged as a consideration in EPR (Extended Producer Responsibility) legislation as it aims to incentivise eco-design, which is the process of taking environmental factors into consideration at all stages of the product development process.
Historically, there has been little financial incentive for producers to improve the environmental impact of their products and packaging. However, recently we are seeing several policies and regulations emerge across the EU, including eco-modulation, to evolve the entire life cycle of plastics in packaging to support the EU’s target of being climate neutral by 2050.
Overview of eco-modulation
Eco-modulation is the notion of penalising the use of materials considered environmentally harmful, such as single-use plastics, and creating incentives or rewards for minimising environmental impacts such as keeping recyclable materials in circulation.
Eco-modulation in recyclability
Eco-modulation features in the Packaging and Packaging Waste Directive (94/62/EC) 2018 amendments (2018/852). It offers economic incentives to increase the use of reusable packaging. This update to the Packaging Directive supports the European Commission’s target to ensure that all packaging will be recyclable or reusable by 2030.
Eco-modulation for recycled content in products
Eco‐modulation can facilitate an increase in the use of recycled materials in products by offering rewards for a higher percentage of recyclable content or by penalising producers that use virgin materials through higher fees.
A variety of policies encourage or mandate recycled content. Currently, discussions are largely around recycled content in plastics. The EU’s Single Use Plastics Directive (SUPD) requires plastic bottles to contain at least 25% recycled plastic by 2025 and 30% by 2030.
Similarly, further revisions to the Packaging and Packaging Waste Directive (94/62/EC) are currently under review in 2023. It will provide mandatory rates of recycled content that producers must include in new plastic packaging. This is in line with commitments taken under the EU plastics strategy and the European Green Deal.
Eco-modulation for reusability
The objective of reusability is to extend the lifespan of products. For packaging, eco-modulation focuses on reusable packaging and a circular system, moving from a use-once-and-throw-away linear approach to a circular economy of eco-designed products where all packaging produced can be safely reused, recycled, or composted.
According to the EU, in 2022 packaging waste increased by more than 20% over 10 years, and for plastic packaging waste an increase of 46% by 2030 is predicted if no action is taken.
Previously, compliance fees focused on items placed on the market and didn’t consider the upstream environmental design of products and packaging. However, we have seen a shift, and eco-modulation will form part of a broader movement to encourage environmental consideration at all stages of the product development process.
Valpak Compliance Services
If your business is affected by environmental legislation in the UK and overseas, Valpak will remove the administrative and resource-intensive burden of complying and offers a range of services that can be tailored to suit your business’s needs.
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