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On 1 January 2026 Poland’s target Extended Producer Responsibility (EPR) rates took effect, announced in the 2024 amendment to the Packaging Act. After two transitional years, the Polish EPR scheme reached a level comparable to Germany’s Grüner Punkt and France’s CITEO — with one clear difference: eco-modulation now spreads fees three-fold depending on real recyclability.
For FMCG producers selling into Poland (and benchmarking the rest of Europe), this means rebuilding the packaging portfolio. A brand still using cheap PVC bottles or PS/EVOH/PE multilayer pays more for the wrapper than for the contents in 2026. A brand that invested in mono-material rPET two years ago receives an eco-modulation rebate of up to 30%.
The new schedule
Base fees per tonne of packaging placed on the Polish market in 2026:
| Material | 2025 (PLN/t) | 2026 (PLN/t) | Δ |
|---|---|---|---|
| Glass | 180 | 230 | +28% |
| Paper / board | 145 | 190 | +31% |
| Aluminium | 195 | 260 | +33% |
| Steel (cans) | 210 | 280 | +33% |
| PET (bottles) | 540 | 780 | +44% |
| HDPE, PP, LDPE | 620 | 920 | +48% |
| Multi-material packaging | 520 | 780 | +50% |
| PS, PVC | 780 | 1 850 | +137% |
The PVC and polystyrene line is the most telling. The Ministry of Climate, in the amendment’s explanatory memorandum, called these polymers “structurally unfit for a closed loop in the municipal stream” and proposed a discouraging fee — high enough that even with cheap virgin resin, packaging becomes uneconomic against alternatives.
Eco-modulation: why rPET wins
Eco-modulation operates across three classes:
- Class A — mono-material packaging, transparent or light-coloured, same-polymer label, adhesive soluble at 85°C. Rebate −25% to −30%.
- Class B — base fee.
- Class C — multilayer, PVC admixture, thermoset adhesives, carbon-black plastic invisible to NIR sorters. Surcharge +30% to +50%.
The maths is simple: a clear PET bottle with 30% food-grade rPET and a shrink-sleeve label of the same PET = Class A = ~550 PLN/t. The same bottle in green PET with a PVC shrink label = Class C = ~1 130 PLN/t. Over 100% difference for the same litre of beverage.
For 5 000 t of annual packaging volume that is nearly PLN 3 million (~EUR 700 k) per year — enough to fund a redesign on its own.
Winners and losers
Winners: bottled water in clear PET, beer in aluminium and glass, milk in unwaxed paperboard cartons. Everyone who invested in mono-material high-recyclability formats years ago.
Losers in 2026:
- Premium cosmetics — HDPE bottles in non-standard pigments (black, metallised), multi-material caps with PVC gaskets. Class C across most of the range.
- Snacks & confectionery — PP/EVOH/PE multilayer films with oxygen barriers. No easy alternative in 2026, but mono-PE with SiOx coatings is being tested.
- Household chemicals — bottles in brand colours with direct print. Surcharges in the low millions per year for the larger brands.
How the industry is reacting
The first 90 days of 2026 show FMCG producers moving in three directions:
- Packaging redesign — Unilever, P&G and L’Oréal have publicly committed to converting 80% of the portfolio to mono-materials by the end of 2027.
- Higher recycled content — the 2027 amendment will add an extra −10% rebate per 25% recycled content. The industry is already pulling forward demand: food-grade rPET prices in Q1 2026 rose 18% vs Q4 2025.
- Price pass-through — retail prices on selected products rose 0.8–1.5% in January 2026. In non-standard segments (premium cosmetics, ready meals) up to 3%.
Administrative burden — SKU-level reporting
A second, often overlooked dimension is SKU-level reporting in the Polish BDO system. Every individual product code (and each packaging variant) must be registered with mass, material and eco-modulation class. For companies with thousands of SKUs this is a sizeable IT project — most are integrating BDO with ERP or buying dedicated compliance modules.
From 1 July 2026, the EU’s PPWR adds a Digital Product Passport QR code on every packaging unit placed on the EU market — linking to material, recycled-content and sorting information in the destination-country language.
Practical recommendation for FMCG buyers
Three steps that genuinely reduce EPR cost today:
- Redesign your three worst SKUs. Typically 80% of portfolio EPR cost comes from 20% of SKUs in Class C. Start there.
- Set a minimum recycled-content level — 30% rPET for beverage bottles, 50% rHDPE for non-food packaging. Supply infrastructure exists at these levels without premium risk.
- Mono-material as the new-project standard — even if it means a thicker single wall instead of a thin three-layer one. Lower EPR more than offsets the resin difference.
Q2 2026 will tell which companies took the new rules seriously and which are waiting for the next exemption. One thing is certain: the status quo costs money, and the cost already shows up in Q1 financial reports.