From 2026, changes to EPR in France - ecomodulation and system bonus-malus

On 1 January 2026, eco-modulation will be introduced in the French EPR system with a bonus-malus model. The financial burden on producers will be modulated due to the recyclate content of packaging and products, but not all of them - as the new rules only apply to 8 of the 22 product categories covered by the EPR rules in France.

The polluter pays and the recycler receives a bonus

The French EPR regulations will be extended to include ecomodulation, a mechanism that makes the amount of the fee subject to (product, ROP) on the environmental impact of the product in question. To encourage manufacturers to use recycled materials, the French government has decided to introduce a financial bonus scheme known more widely as bonus-malus. From January 2026. producers will receive a bonus for each tonne of recyclate consumed in the manufacture of selected EPR products.

In France, the eco-modulation scheme will be covered:

• wrapping and packaging, printed paper (except books) and graphic paper,
• packaging used in the B2B sector,
• electrical and electronic equipment,
• chemical products and packaging from chemicals (e.g. adhesives, silicones, solvents, paints, varnishes and impregnants, plant protection products, fertilisers, dyes, pigments and inks),
• furniture, including upholstered furniture and textile decorative articles,
• toys,
• sports and leisure goods,
• DIY products and gardening equipment and accessories.

Read also: Ecomodulation in e-commerce: what do online shops and packaging manufacturers need to know?

Producer bonuses are to be financed entirely by extended producer responsibility levies. They will be granted on the basis of information on the quantities of recyclate in products and packaging provided by producers and subsequently verified by producer responsibility organisations (PBOs). éco-organismes).

The changes to the French EPR system result from the decree of 5 September 2025 establishing the modulations applicable to the financial contributions paid by producers when they contain recycled plastics (fr. Arrêté du 5 septembre 2025 fixant les modulations applicables aux contributions financières versées par les producteurs lorsqu'ils incorporent des matières plastiques recyclées), which will enter into force on 1 January 2026.

Between €450 and €1,000 rebate for using recyclate

The cited regulation also sets out the rates of bonuses of which the the amount depends on the origin of the recyclate and the complexity of the recycling process, where the secondary raw material in question was produced.

Producers subject to EPR obligations can receive a rebate of:

• 550 EUR per tonne of recyclate used, if obtained from the processing of products of the same type, as the product introduced by the manufacturer,
• EUR 450 per tonne of recyclate used if it comes from the processing of other products covered by the EPR scheme in France,
• EUR 1,000 (EUR 550 in 2026 and 2027) per tonne of used recyclate derived from waste plastics that are considered technically difficult to recycle. This category also includes plastics for contact applications, which include, among others, recyclates of PET (excluding raw material obtained from recycled PET bottles), EPS (excluding foamed polystyrene), PP, HDPE and LDPE.

For most products and packaging covered by the EPR no minimum percentage or weight level of recyclate has been set, on which the rebate will be calculated. A producer can therefore receive a premium even for products containing only minimal amounts of recyclate (e.g. in 1%). From this rule however, there are two exceptions - These include plastic beverage bottles made of transparent, coloured and opaque PET and HDPE. For both types of packaging, the regulation establishes an obligation to use certain levels of recyclate, amounting to:

• for PET bottles - 25% until 31 December 2029 and 30% from 1 January 2030,
• for HDPE bottles - 0% until 31 December 2029 and 30% from 1 January 2030.

In the case of these packages, the ecomodulatory the premium will only be charged on quantities of recyclate exceeding the minimum indicated.

Read also: Ecomodulation in the PPWR - what will modulated packaging charges look like?

Efficient recycling and the proximity principle as additional bonus conditions

In addition to the use of recyclate, it will also be necessary to realise all stages of waste management and new product manufacture for the eco-modulation bonus to be awarded:

• within a radius of no more than 1 500 kilometres from the centre of France as described in the act in the form of geographical coordinates,
• in another EU Member State or in a third country meeting equivalent EU environmental standards.

In addition, products made from composites, plastics containing additives or substances that make it difficult to recycle, recycled PVC or recyclate obtained from an insufficiently efficient recycling process (recovery of less than 50% by weight of waste) will be excluded from the bonus scheme.

Find out more about the principles of ecomodulation in France >>