Postponement of the German Plastic Tax until 2025 – Overview of Tax Regulations for Plastic Packaging in Europe

Currently, the spotlight in media coverage is on the announced budgetary austerity measures for Germany in 2024, which the coalition government has recently revised. A significant change affects the plastic industry, as it faces the introduction of a plastic tax for plastic packaging manufacturers. Previously, these taxes were covered by EU-level tax funds; however, the reform mandates that the producers now bear these costs. Initially planned for immediate implementation, the much-debated plastic tax on packaging in Germany has now been postponed to 2025. But what about other EU countries? Some have already imposed taxes on plastic packaging, payable by the packaging producers. How has the situation there evolved? What are the effects of these taxes, especially on the volume of packaging and the proportion of recycled materials in the products? Key metrics communicated with the introduction of the taxes and their regulatory impact are examined, using the UK and Spain as examples.

In the UK, a tax was introduced 2022 on plastic packaging containing less than 30% recycled material. In the last fiscal year 2023 (April to April of the following year), the UK government collected 323 million EURO in taxes on plastic packaging. The rate is set at 210.82 GBP/ton (currently about 245 EURO/ton). This rate is scheduled to increase again on April 1, 2024, to 217.85 GBP/ton. Currently, there is no statistical data on whether the introduction of the plastic tax has led to an increased use of recycled materials. The tax applies to imported and domestically produced quantities, with about 48 % attributable to imports. Under the Extended Producer Responsibility (EPR) scheme, another levy was to be introduced in 2024 based on the amount and material of the packaging used; however, this has been postponed to 2025. The law underlying the packaging tax contains detailed information that can be accessed.

In Spain, the Ley 7/2022 Impuesto especial sobre los envases de plástico no reutilizables (Law 7/2022 Special Tax on Non-Reusable Plastic Packaging) was enacted for 2023. The Spanish tax is levied on both domestically produced and imported packaging. Unlike the UK tax, the regulation does not include a minimum amount of recycled content. The tax is charged per kilogram of non-recycled plastic in the packaging at a rate of 0.45 EURO per kilogram. There is currently a lack of data regarding the impact of the tax on the percentage of recycled material in plastic packaging. Furthermore, there is no information available for Spain regarding the revenue generated from the tax in the year 2023.

Part of the law also includes the incorporation of Extended Producers Responsibility (EPR). The subsequent Royal decree on packaging and packaging materials specifies the definitions for implementing the law and targets for prevention, reuse, and recycling of packaging. The decree's announcement also specified the precise commencement of the take-back systems for packaging for December 2024. Additional information can be obtained from the website of the Spanish tax authorities.

In the context of a consultancy project, RIGK plays an active role in implementing the take-back system for industrial and commercial packaging in Spain, Envalora. Envalora is the Spanish take-back system (Sistema Colectivo de Responsabilidad Ampliada del Productor, SCRAP) for industrial and commercial packaging in the chemical, plastic, rubber, and construction industries, with over 200 companies participating. The system has been operational since the beginning of 2024.

In another EU country where the introduction of a plastic tax has been a subject of recurrent discussion is Italy. The planned tax of 0.45 EURO per kilogram of single-use plastic products, originally slated for the year 2020, has once again been postponed. According to the Italian budget legislation of 2022, the tax is now set to come into effect on January 1, 2024. This measure targets manufacturers, importers, and purchasers of single-use plastic products.

Further Information:

Jan Bauer
Managing Director, RIGK GmbH
+49 611 308600-16
bauer(at)rigk.de