Fees and eco-modulation

    Malus (fee penalty)

    A surcharge applied to EPR fees for packaging with recognised recyclability problems, such as dark pigments or non-separable multi-material construction.

    A malus is the penalty half of eco-modulation. Typical triggers are pigments that defeat optical sorting, PVC components, full-body sleeves above a coverage threshold, non-separable multi-material laminates, and adhesives that contaminate fibre streams.

    Penalty rates are usually expressed as a percentage uplift on the base rate or as a per-unit surcharge. In the most aggressive schedules a malus can exceed the base fee itself, which makes a single component decision, for instance a sleeve material, financially material at portfolio scale.

    Because the malus attaches to a defined design attribute, it is one of the few compliance costs a company can remove entirely through a specification change rather than a filing change.

    Go deeper

    Related terms

    • Eco-modulation

      Adjusting EPR fees up or down according to the environmental performance of the packaging, rewarding recyclable design and penalising problem formats.

    • Bonus (fee reduction)

      A discount on EPR fees granted for verified environmental improvements such as recycled content, mono-material design or weight reduction.

    • Design for recycling (DfR)

      Designing packaging so it can be collected, sorted and reprocessed at scale, and under PPWR a legal requirement graded from A to E.

    Back to the full glossary

    See this in your own packaging data

    Packgine resolves your packaging to component level and applies the rules of every market you sell into.