Compliance Contributions Overview 2020 - EXPRA

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Compliance Contributions Overview 2020 - EXPRA
2020

Compliance Contributions Overview

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Contents
Introduction .................................................................................................................................................. 2
1. Belgium: Fost Plus ..................................................................................................................................... 3
2. Belgium: VAL-I-PAC (responsible only for industrial and commercial packaging) .................................... 6
3. Bosnia and Herzegovina - Ekopak ............................................................................................................. 7
4. Bulgaria: ECOPACK .................................................................................................................................... 8
5. Canada: Éco Entreprises Québec .............................................................................................................. 9
6. Green Dot Cyprus .................................................................................................................................... 12
7. Czech Republic: EKO-KOM ...................................................................................................................... 13
8. Estonia: ETO ............................................................................................................................................ 16
9. Finland: FINISH PACKAGING RECYCLING RINKI LTD. ............................................................................... 17
10. Greece: HE.R.R.Co. ................................................................................................................................ 19
11. Hungary: ÖKO-Pannon .......................................................................................................................... 20
12. Italy: CONAI ......................................................................................................................................... 22
13. Israel: TAMIR ......................................................................................................................................... 23
14. Luxembourg: Valorlux ........................................................................................................................... 24
15. Macedonia: PAKOMAK d.o.o ................................................................................................................ 25
16. Malta: GreenPak ................................................................................................................................... 26
17. The Netherlands: Afvalfonds Verpakkingen ......................................................................................... 27
18. Norway: Grønt Punkt ............................................................................................................................ 30
19. Romania: ECO-ROM AMBALAJE ............................................................................................................ 32
20. Slovakia: ENVI-PAK ................................................................................................................................ 33
21. Slovenia: Slopak .................................................................................................................................... 34
22. Spain: ECOEMBALAJES ESPAÑA, S.A. (ECOEMBES) ............................................................................... 35
23. Spain: ECOVIDRIO ................................................................................................................................. 37
24. Sweden: FTI ........................................................................................................................................... 38
25. Turkey: CEVKO ...................................................................................................................................... 39

                                                                                                                                                                    1
Introduction

Every country has implemented the European Packaging Directive in a different way, inter alia putting different
obligations to obliged industry. Therefore, the costs for compliance with obligations contain different factors
affecting the cost levels which should be taken into account when comparing the relative costs of compliance across
various European schemes.
Key factors influencing relative compliance costs include the following:

•   Existing collection and recovery infrastructure in the waste management sector.

•   Packaging sources being used to meet national recycling quotas (household only or all packaging): household
    packaging waste is more expensive to collect and recover than packaging waste arising at industry’s back door.

•   Proportionate share of costs being borne by industry. This can be the full costs for collection, sorting and recovery of
    used packaging up to the so called additional costs for the separate collection and sorting.

•   Respective recycling quotas and the effect of derogations.

•   Collection systems used affect charges: bring systems are generally less expensive than door-to-door collection,
    but they usually collect less packaging.

•   Geographic location and population density: remote and sparsely populated regions will generally be more
    difficult and expensive to collect from.

•   Enforcement regimes influence costs; the more companies who participate in the scheme, the greater the spread
    of the cost base.

•   Labour costs and general overheads differ depending on the prevailing local economic conditions.

Just recently, the new Waste Framework Directive introduced a number of changes, among which the concept of
‘EPR schemes’. Under their scope, eco-modulation has become an obligation to boost packaging recyclability under
the general, minimum requirements outlined for these schemes. The new Waste Directive calls for the fees to be
modulated, where possible, for individual products or groups of similar products. EXPRA is currently conducting a
research on the various approaches that could be feasible and comparable, with a specific focus on the “product
category”.

A first assessment of this exercise shows that some compliance schemes have already moved onto introducing
additional fee modulation. The latter generally follows an approach based on the “shared balance sheet according to
the economic cost of packaging recyclability”.

This document gives an overview of the current costs for compliance with the respective national recovery systems
for packaging and packaging waste. All data have been sent to EXPRA by the respective systems (as of March 2020),
and have been compiled to the best of our knowledge. Nevertheless, this information is subject to change at any time,
especially in the light of the COVID 19 crises and we therefore cannot guarantee its accuracy and applicability to each
type of packaging. We therefore kindly ask you to get in touch with the respective system of your country of operation
to obtain the latest information relevant to you.

Should you have any further question, please feel free to contact me via phone or e-mail.

Best regards,

Joachim Quoden
Managing Director of EXPRA

                                                                                                                          2
1. Belgium: Fost Plus
2021 Compliance tariffs per material in EUR / kg:

Materials                                     Category                                    Rate (EUR/kg) excl. VAT

                                                           Recycled
Glass                                                                          001                    0,0499
Paper-cardboard (> 85%)                                                        002                    0,1189

Steel (> 50%)                                                                  003                    0,2114
Aluminium (> 50% and > 5op)                                                    004                    0,0462

Beverage cartons                                                               008                    0,4453

PET - Bottles and flasks - Transparent colourless                             005-01                  0,2004
PET - Bottles and flasks - Transparent blue                                   005-02                 0,3297

PET - Bottles and flasks - Transparent - other than colourless and blue   005-03 / 011-04             0,4706

PET - rigid packaging other than bottles and flasks - Transparent             011-05                 1,1337

HDPE - Bottles, flasks and other rigid packaging                           007 / 011-03               0,3647
PP - Bottles, flasks and other rigid packaging                                011-01                  0,4754

PS - Hard packaging, except for EPS                                           011-02                  0,9968

PE - Films                                                                    011-07                  0,9102
Other plastics - Films, except for compostable                                011-09                  0,9102

                                                          Valorised
Composite materials in which paper-cardboard accounts for the
greatest weight                                                                012                    1,1520
Aluminium smaller than 5op, non-composite                                      013                    1,1520

PET - Bottles and flasks - Opaque                                             011-06                  1,1520
Other plastics - Hard packaging, except for compostable plastics and
                                                                              011-08
EPS                                                                                                   1,1520
Other plastic packaging - whether or not composite - where plastic
accounts for the greatest weight, including compostable plastics and           014                    1,1520
EPS
Wood, cork, textile, ...                                                       016                    1,1520

                                                         Non-valorised

Composite packaging in which glass accounts for the greatest weight            017                    1,4400

                                                                                                                    3
Composite packaging in which steel accounts for the greatest weight         018                   1,4400
Pottery, ceramics, porcelain, ...                                           019                   1,4400

                                           Hazardous household waste (HHW)
Household packaging that must be sorted as HHW after use                                         1,1133

                                                  Obstructive packaging
Household packaging that obstruct the collection, sorting or recycling                            2,2674

How do you apply the Green Dot rates?
General rules:
    ❖ All packaging elements must be declared based on their material category.
Examples:
❖ Jam packaged in a glass jar with a label and a lid. The jar must be declared at the ‘glass 001’ rate, the label at
   ‘paper-cardboard 002’ and the lid at ‘steel 003’.
❖ Smartphone packaged in a cardboard box. The cardboard box should be declared as ‘paper-cardboard 002’.
   The charger and the earphones are each in a separate PE-bag with a paper label. These bags should be
   declared in the ‘PE films 01107’ category, the two labels in the ‘paper-cardboard 002’ category.
❖   Distinction between hard and soft packaging.
    a. Hard or rigid packaging will automatically return to its original shape after buckling. This includes bottles,
       flasks, containers, pots, trays and other blow-moulded or injection moulded plastic packaging. Hard
       packaging is usually comprised of dimensionally stable packaging which may or may not be combined with
       various packaging elements which can be separated from the actual packaging (e.g. label, cap, lid, sealing
       foil).
    b. Soft or flexible packaging is not rigid and buckles easily. It includes sacks, bags, envelopes, stand-up
       ppouches, removable sealing films, wrappers and similar flexible packaging articles. Soft or flexible
       packaging consists of one or more layers made of a variety of materials, including plastic film, paper,
       aluminium or a combination of these. The construction may be unprinted, printed, coated and/or
       laminated.

    ❖ Distinction is made between transparent versus opaque PET-packaging.
    a.   With transparent PET packaging, its content is clearly visible through the material.
    b.   With non-transparent or opaque PET-packaging, its content is not or barely visible through the material
    ❖ Distinction between colourless versus coloured transparent PET-bottles and flasks.
    a.   Most transparent PET-bottles and flasks are colourless which means that they have not been coloured, eg
         by adding a colouring pigment
    b.   The coloured transparent PET-bottles and flasks were coloured by the producer, eg by adding a colouring
         pigment. The transparent coloured PET-bottles are split in blue, green or other colours. The colour of the
         PET-bottle is best seen at the injection point (at the bottom of the bottle) or in the neck (on which the
         closures fit)

    ❖ The “Hazardous Household Waste” rate applies to the following household packaging that has to be sorted as
      HHW after use: :
    ❖ Packaging of paints, lacquers and varnishes
    ❖ Packaging of glues, silicones and resins
    ❖ Packaging of lubricating oils, fuels, engine oils and mineral oils
    ❖ Pesticide packaging (herbicides, insecticides, fungicides, ...)
    ❖ Disposable gas cylinders and metal aerosols, except for aerosols for cosmetics or food
    ❖ Packaging with compulsory child-resistant closure (CRC)

                                                                                                                        4
RECYCLED                                                             VALORISED
•   Glass (001): applies for bottles, flasks and jars in glass.      •   PET - Bottles and flasks - Opaque (011-06): applies
    This does not apply for packaging in Pyrex, crystal or               for bottles and flasks in non-transparent PET.
    natural opal glass that contains more than 600 ppm               •   Other Plastics - Hard packaging, with exception of
    fluorine.                                                            EPS and compostable (011-08): applies for hard
•   Paper-cardboard (002): applies for all packaging ele-                packaging elements consisting exclusively of plastic
    ments in paper-cardboard that consist of at least 85%                that do not fall under the previous material
    paper fibre.                                                         categories. This includes e.g. non-transparent PET
•   Steel (003): applies for all packaging elements that con-            trays and hard plastic packaging consisting of
    tain more than 50% steel.                                            various types of polymers.
•   Aluminium (004): applies for all packaging elements that         •   Category 012 to 016: applies for all packaging
    contain more than 50% aluminium in weight and have a                 elements that do not fall under the application
    thickness greater than or equal to 50 p.                             conditions of the previous material categories, but
•   Drinks cartons (008): applies for any packaging element              are valorised:
    in laminated cardboard - with or without a cap - that con-           - 012: composite packaging in which paper-
    sists       of       cardboard/plastic/aluminium            or          cardboard accounts for the greatest weight
    cardboard/plastic, with a minimum of 50% paper fibre.                   (total paper fibre < 85%).
    This is usually used to package liquids, mainly dairy                - 013: Packaging made of aluminium thinner than
    products and fruit juices.                                              50p.
•   PET - Bottles and flasks - Transparent, colourless (00501):          - 014: Other packaging - whether or not
    applies for colourless bottles and flasks in transparent                composite - where plastic accounts for the
    PET.                                                                    greatest weight, eg
•   PET - Bottles and flasks - Transparent, blue (005-02):                     » Laminated plastic packaging with an
    applies for blue bottles and flasks in transparent PET.                       aluminium film
•   PET - Bottles and flasks - Transparent, green (005-03):                    » EPS (styrofoam), packaging from other types
    applies for green bottles and flasks in transparent PET.                      of plastic (eg PVC) and compostable plastics
•   PET - Bottles and flasks - Transparent - Other than                  - 016: Wood, cork, textile, ...
    colourless, blue or green (011-04): applies for bottles
    and flasks in transparent PET, with another colour than          NON-VALORISED
    colourless, blue or green.
•   PET - Hard packaging other than bottles and flasks -             •   Category 017 to 019: applies for all packaging
    Transparent (011-05): applies for hard packaging ele-                elements that do not fall under the application
    ments, other than bottles and flasks, which consists of              conditions of the previous material categories:
    transparent thermoformed PET, like trays, cups and so                - 017: Composite packaging in which glass
    on; note, this category does not apply for opaque                       accounts for the greatest weight, e.g. packaging
    thermoformed PET for which the category ‘011-08                         in pyrex, crystal or opal glass that contains more
    Other plastics - hard packaging’ applies.                               than 600 ppm fluorine
•   HDPE - Bottles and flasks (007): applies for bottles,                - 018: Composite packaging in which steel
    flasks and caps in HDPE.                                                accounts for the greatest weight
•   HDPE - Hard packaging other than bottles and flasks                  - 019: Pottery, ceramics, porcelain,
    (011-03): applies for hard packaging elements other
    than bottles, flasks and caps, consisting of HDPE.
•   PP - Bottles, flasks and other hard packaging (011-01):
    applies for hard packaging elements consisting of PP,
    including bottles, flasks and caps.
•   PS - Hard packaging, with exception of EPS (011-02):
    applies for hard packaging elements consisting
    exclusiely of PS, except for EPS (styrofoam) for which                    INFO:
    the category ‘valorised 014’ applies.                                     The contribution per packaging unit (as
•   PE - Films (011-07): applies for flexible packaging ele-                  described on 1 packaging file) amounts to
    ments of PE.                                                              at least EUR 0.000001. If the weight-based
•   Other Plastics - Films (011-09): applies for other flexible
    packaging elements consisting exclusively of plastic,                     contribution is lower, it will be increased to
    other than exclusively PE, except for compostable                         EUR 0.000001
    plastic packaging and aluminium film laminated plastic,
    both for which the ‘valorised 014’ category applies.

    More information can be found here

                                                                                                                                 5
2. Belgium: VAL-I-PAC (responsible only for industrial and commercial packaging)

The annual charge per declaration type is calculated depending on:

   •   the type of material which you put on to the market/for which you are responsible (e.g. plastic)
   •   its properties (recyclable or not)
   •   the amount of material (number of tonnes)

 Packaging material                                   2020 tariff per tone

 Recyclable cardboard                                 14,50
 Recyclable metal                                     14,50
 Recyclable wood                                      14,50
 Recyclable glass                                     14,50
 Recyclable natural fibers                            14,50
 Recyclable plastic                                   39,50
 Recyclable plastic from the construction             49,50
 industry
 Other recyclable materials                           14,50
 Non-recyclable materials (including non-             53,00
 recyclable plastic)

   •   this table refers to the cost of the declaration with effect from the year of membership (tariff as at
       01.01.2020)
   •   Retroactive membership
       A special retroactive fee is levied in the first year of membership. The VAL-I-PAC system is open to
       companies which wish to regularize their position with respect to the take-back and information
       obligation. VAL-I-PAC has to apply a retroactive membership fee for the five calendar years prior to the
       year of joining.

The minimum funding contribution is 50 Euros per year (or 250 Euro for the retroactive membership fee for the
five calendar years prior to the year of joining).

                                                                                                                  6
3. Bosnia and Herzegovina - Ekopak

   Packaging fees for 2020
                                                      Compliance Costs*                Compliance Costs*
               Packaging material
                                                         (BAM /ton)                        (€/ton)
    Glass                                                    25                             12,78

    Metal                                                                                    9,20
                                                               18

    Paper                                                      25                            12,78

    Plastic                                                    35                            17,89

    Wood                                                       16                            8,18
    Multilayer, and/or other materials                         30                            15,33

    Packaging containing and /or                               34                            17,38
    contaminated by hazardous materials

     * VAT 17% is not included

     1 EUR = 1,95583 BAM

     Note: Clients of Ekopak can reduce costs up to 15% through the loyalty program.

                                                                                                           7
4. Bulgaria: ECOPACK 2020

                                                                   After 10%          After additional
                                                                  discount for        20% discount for
                                                Base             timely report        timely payment
                       Material
                                            Compliance cost     submission (15th
                                                                   day of the          (25th day of the
                                                                    month)                 month)

            Plastics                              0.137               0.123                  0.099

            Paper and Cardboard                   0.145              0.1305                  0.104

            Glass                                 0.165              0.1485                  0.119

            Metals                                0.041               0.037                  0.0295

            Aluminum                              0.089               0.080                  0.064

            Composites                            0.194               0.175                  0.140

            Wood                                  0.098               0.088                  0.071

            Others                                0.259               0.233                  0.186

Fees are in BGN, per kilogram, excluding VAT

Indicated fee discounts apply only for reported quantities in excess of 10 tons per annum.

Minimum annual fee for 1 obliged company BGN 150, excluding VAT
EUR 1 = BGN 1,95583

                                                                                                          8
5. Canada: Éco Entreprises Québec

 Schedule 2019                                                   Reference Year : 2018
 CLASS and Material                                                     ($/tonne)
 PRINTED MATTER
 Newsprint inserts and circulars printed on news paper                   203,74
 Catalogues and publications                                             293,65
 Magazines                                                               293,65
 Telephone books                                                         293,65
 Paper for general use                                                   293,65
 Other printed matter                                                    293,65
 TOTAL - PRINTED MATTER                                                  234,15

 CONTAINERS AND PACKAGING
 Paperboard
    • Corrugated cardboard                                              182,70 $
    • Kraft paper shopping bags and paper packaging                     182,70 $
    • Boxboard / Other paper packaging                                  200,23 $
    • Gable-top containers                                              190,50 $
    • Paper laminants                                                   286,73 $
    • Aseptic containers                                                233,71 $
         TOTAL - Paperboard                                             201,06
 Plastic
    • PET bottles                                                        283,38
    • HDPE bottles                                                       108,44
    • Plastic laminants                                                  471,46
    • HDPE and LDPE plastic film                                         471,46
    • HDPE and LDPE plastic shopping bags                                471,46
    • Expanded polystyrene food                                          789,39
    • Expanded polystyrene protection                                    789,39
    • Non-expanded polystyrene                                           789,39
    • PET containers                                                     283,38
    • PVC, Polylactic acid (PLA) and other degradable plastics           789,39
    • Other plastics, polymers and polyurethane                          286,18
         TOTAL - Plastic                                                 357,19
 Aluminium
    • Aluminium containers for food and beverages                        179,87
    • Other aluminium containers and packaging                           179,87
         TOTAL - Aluminium                                               179,87
 Steel
    • Steel aerosol containers                                           171,61
    • Other steel containers                                             171,61
         TOTAL - Steel                                                   171,61
 Glass
    • Clear glass                                                        172,18
    • Coloured glass                                                     172,26
         TOTAL - Glass                                                   172,23

                                                                                         9
TOTAL - CONTAINERS AND PACKAGING                                                        236,99

 TOTAL                                                                                   236,37
$1.4503CAN = 1 EURO (Bank of Canada – 2020-01-03)

* For the calculation of the contribution for the 2019 Obligation Year, the Targeted Persons must declare the
materials that were marketed in Québec for the twelve (12) months comprised between January 1st and December
31st of the Reference Year, which is 2018.
* A credit of 20% for the payable contribution is granted to Targeted Persons that generate materials of which the
percentage (%) of recycled post-consumer content reaches or exceeds the established benchmark, when the
Materials report is submitted within the prescribed delays. The credit is granted by way of a distinct invoice that is
issued in the year following the deadline to submit the Materials report. The appropriate documentation and
samples to determine the content of post-consumer recycled material must be provided to Éco Entreprises Québec
before the first deadline date to pay the contribution. The content of the recycled material is an element which is
taken into consideration when calculating the payable contribution pursuant to section 53.31.14, paragraph 2 of
the Environment Quality Act.

Options to facilitate compliance with small companies and low volume producers
The following table presents the flat fees for the 2019 Schedule of Contributions :

  Options for low-volume producers        2019 Schedule                              Rates

                                                        1 to ≤2.5 tonnes                 $450
  Based on tonnage                                  >2.5 to ≤5 tonnes                 $945
                                                    >5 to ≤10 tonnes                 $1885
                                                    >10 to ≤15 tonnes                $3150
                                                          ≤ $1 M                       $0
  Based on sales
                                                     >$1 M to ≤ $2 M                 $3150

  Based on the number of points of
                                           = 1 point of retail service
* For the calculation of the contribution for the 2018 Obligation Year, the Targeted Persons must declare the
materials that were marketed in Québec for the twelve (12) months comprised between January 1st and December
31st of the Reference Year, which is 2017.
* A credit of 20% for the payable contribution is granted to Targeted Persons that generate materials of which the
percentage (%) of recycled post-consumer content reaches or exceeds the established benchmark, when the
Materials report is submitted within the prescribed delays. The credit is granted by way of a distinct invoice that is
issued in the year following the deadline to submit the Materials report. The appropriate documentation and
samples to determine the content of post-consumer recycled material must be provided to Éco Entreprises Québec
before the first deadline date to pay the contribution. The content of the recycled material is an element which is
taken into consideration when calculating the payable contribution pursuant to section 53.31.14, paragraph 2 of
the Environment Quality Act.

Options to facilitate compliance with small companies and low volume producers
The following table presents the flat fees for the 2018 Schedule of Contributions:

  Options for low-volume producers        2018 Schedule                              Rates

                                                        1 to ≤2.5 tonnes                 $420
  Based on tonnage                                  >2.5 to ≤5 tonnes                 $890
                                                    >5 to ≤10 tonnes                 $1775
                                                    >10 to ≤15 tonnes                $2965
                                                          ≤ $1 M                       $0
  Based on sales
                                                     >$1 M to ≤ $2 M                 $2965

  Based on the number of points of
                                                = 1 point of retail service            $0
  retail service

Targeted Persons

To be considered as a targeted person, a company should meet the following three criteria:
• It generates containers, packaging and/or printed matter ultimately intended for Quebec consumers;
• It has a place of business or an establishment in Quebec;
• It is the owner of a brand, a name or a distinguishing guise.

However, if the owner has no domicile or establishment in Québec, the first supplier in Québec of the products, or
the containers and packaging, or of the printed matter, other than the manufacturer, may be required to pay the
contribution, whether or not that supplier is the importer.

Éco Entreprises Québec may accept that a third party whose domicile or establishment is outside Québec and
who is the owner of a brand, a name or a distinguishing guise becomes a voluntary contributor. A third party may
be recognized as a voluntary contributor after having concluded an agreement with Éco Entreprises Québec to this
effect.

                                                                                                                    11
6. Green Dot Cyprus

                 Material                   EUR per tonne

Household Packaging                             2013

Glass                                           27,61

Carton                                          44,78

Metal                                          90, 62

Aluminium                                       20,31

PET                                            100,60

HDPE                                           100,60

Cardboard Liquid Containers                    116,61

Other reusable                                 124,50

Other non-reusable                             149,41

Commercial/Industrial Packaging

Corrugated carton                               41,14

Plastic                                         36,04

Wood                                            11,80

Other                                           47,70

                                                            12
7. Czech Republic: EKO-KOM

              Remuneration structure for ensuring compliance with the obligation to return and
                            recovery of packaging waste through the EKO-KOM

                                                 Reusable packaging1          One-way packaging2
                      Valid from 1.1.2020
                                                CZK/t         EUR/t*           CZK/t      EUR/t*
                      Soft plastics                  0,00              0,00           5 848        224,92
                      Rigid plastics                 0,00              0,00           5 848        224,92
                      Rigid plastics above 5L        0,00              0,00           4 386        168,69
                      Corrugated board               0,00              0,00           2 426         93,31
                      Paper                          0,00              0,00           2 586         99,46
    Sales packaging

                      Glass                          0,00              0,00           1 930         74,23
                      Metals Fe                      0,00              0,00           2 004         77,08
                      Metals Al                      0,00              0,00           2 666        102,54
                      Metals above 5L                0,00              0,00           1 106         42,54
                      Beverage cartons               0,00              0,00           4 478        172,23
                      Combined materials             0,00              0,00           6 346        244,08
                      Wood                           0,00              0,00           1 199         46,12
                      Textile                        0,00              0,00           1 199         46,12
                      Others                         0,00              0,00           6 346        244,08
                      Plastics                       0,00              0,00             632         24,31
                      Corrugated board               0,00              0,00             326         12,54
    Group packaging

                      Paper                          0,00              0,00             326         12,54
                      Metals Fe                      0,00              0,00             542         20,85
                      Metals Al                      0,00              0,00             542         20,85
                      Combined materials             0,00              0,00             632         24,31
                      Wood                           0,00              0,00             343         13,19
                      Textile                        0,00              0,00             343         13,19
                      Others                         0,00              0,00             632         24,31
                      Plastics                       0,00              0,00             632         24,31
                      Corrugated board               0,00              0,00             326         12,54
    packaging
    Transport

                      Paper                          0,00              0,00             326         12,54
                      Metals Fe                      0,00              0,00             542         20,85
                      Metals Al                      0,00              0,00             542         20,85
                      Combined materials             0,00              0,00             632         24,31

1

4
 Reusable packaging, to meet § 13 Article 2 of Act No. 477/2001 Coll., as amended by later regulations
2
 Packaging which does not meet § 13 Article 2 of Act No. 477/2001 Coll., as amended by later regulations.
* Payments are made in CZK. Exchange rate of January, 2020 is: 1 EUR ~ 26 CZK

                                                                                                            13
Wood                  0,00                0,00               343         13,19
                        Textile               0,00                0,00               343         13,19
                        Others                0,00                0,00               632         24,31
                        Plastics              0,00                0,00               632         24,31
                        Corrugated board      0,00                0,00               326         12,54
 Industrial packaging

                        Paper                 0,00                0,00               326         12,54
                        Glass                 0,00                0,00             1 930         74,23
                        Metals Fe             0,00                0,00               542         20,85
                        Metals Al             0,00                0,00               542         20,85
                        Combined materials    0,00                0,00               632         24,31
                        Wood                  0,00                0,00               343         13,19
                        Textile               0,00                0,00               343         13,19
                        Others                0,00                0,00               632         24,31

Compliance cost discount based on the Article VI., Paragraph 7                       500         19,23
of the Contract
Compliance  costonunder
                   Collective   Compliance
                          the Agreement     on(per year)
                                               Comprehensive                       1 600         61,54
Fulfilment of Part III., Article VI, valid from 1.1. 2011 (per year)
Compliance cost for registration in the system of collective compliance

1) Reusable packaging, to meet § 13 Article 2 of Act No. 477/2001 Coll., as amended by later regulations
2) Packaging which does not meet § 13 Article 2 of Act No. 477/2001 Coll., as amended by later regulations

*) Payment are paying in CZK. Exchange rate of 2020 is: 1 EUR ~ 26 CZK
!!! The fees in EUR are just for information!!!

DEFINITION:

One-way packaging

Packaging which do not meet the requirements of the Section 13, article No. 2 of Act No. 477/2001 Col. as amended
by later regulations e.g. package for milk, juice, biscuits).

Reusable packaging

Packaging which meet the requirements of the Section 13, article No. 2 of Act No. 477/2001 Col. as amended by
later regulations. It is the packaging which executes a specific minimal number of rotations or cycles during its
lifecycle; it is re-filled or re-used. That definition is met, for example, by palette, a plastic container, a beer bottle, a
gas bottle, etc.

The difference between soft plastic packaging and rigid plastic packaging

The group of solid hollow plastic comprises all plastic beverage packaging (for example, PET bottles). It also
includes blown detergent bottles, fabric softener bottles, etc. The group of soft packaging comprises all the types of
packing foils, bags and very light packaging.

Combined materials

In case of packaging which consists of a few parts of various materials it is problematic to weight those components
accurately; (that applies, for example, to a glass bottle metal cap, an aluminium aerosol can metal cap, a paper label,
a self-adhesive label on packaging, plastic cap, etc.). The §48 of the Packaging Act specifies that in case of record-
keeping in accordance with the §15 of the Act packaging containing one type of specific material which represents
at least 70 per cent of the packaging weight is viewed as one material packaging. Therefore, for example, a glass
bottle + a metal cap + a paper label are viewed for those purposes as consumer packaging of one material - glass.

                                                                                                                           14
Similarly, in case of an aerosol can, an aluminium container + a metal cap + a plastic pressure sprayer + a plastic cap
+ a vinyl self-adhesive label are viewed for those purposes as consumer packaging made of aluminium (providing,
aluminium represents more than 70 per cent of the total weight). In case of a big production firm it is possible and
correct to report those items separately.

In the case that any part of the package does not exceed 70% by weight, it is necessary to cover in the statement
included in the box combined materials. The same box can be placed on the packaging and combined materials
(packaging of the components made of different materials that cannot be manually separated from each other) as
packaging for fresh butter (aluminium foil, paper) cups for dairy products (paper, plastic film) or blister from drugs.

                                                                                                                    15
8. Estonia: ETO

Compliance costs for of ETO, 2020

                                                                 € per kg
                                   € per kg
 Material
                                                                 Bundling and
                                   commercial
                                                                 transport

 Plastics                             0.102                        0.093

 Cardboard                            0.105                        0.109

 Glass                                0.409                        0.128

 Metal                                0.255                        0.041

 Wood                                 0.041                        0.093

 Other                                0.102                        0.109

VAT will be added to the service fees in amount of 20%.

Reusable packaging is not charged as long as being in reuse.

For further details please contact eto@eto.ee or visit eto.ee.

                                                                                16
9. Finland: FINISH PACKAGING RECYCLING RINKI LTD.

RINKI LTD’S REGISTRATION AND CUSTOMER FEES
The customer fee invoicing will be based on the price list and the packaging quantities the company used the
previous year. There will be no registration fee in 2020.

 Fee type                 Fee *               Unit
 Customer fee             1.60                €/ton
 Customer fee, minimum 265                    €/year/contract
 Customer fee, maximum 4 500                  €/year/contract
 Registration fee         0                   €/company
*) Value added tax is added to the fees.

RECYCLING FEES FOR PACKAGING
The company’s material-specific recycling fees in 2020 are based on the 2020 recycling fees below, as well
as the company’s 2019 packaging volumes.

MATERIAL                                             Recycling fee *
                                                     €/ton
FIBRE         Corrugated cardboard packaging for     9.50
              consumers
              Corrugated cardboard packaging for     9.50
              firms
              Industrial wrapping and sacks          14.00
              Industrial cores                       14.00
              Carton and paper packaging             49.50
              Carton liquid packaging                105.00
PLASTIC       Plastic packaging for consumers:
              Conventional plastic packaging **      119.00
              Biodegradable plastic packaging        119.00
              Conventional shopping bags **          119.00
              Biodegradable shopping bags            119.00
              Conventional small bags **             119.00
              Biodegradable small bags               119.00
              Plastic packaging for firms            54.00
METAL         Aluminium packaging for consumers      126.00
              Aluminium packaging for firms          26.00
              Tinplate packaging for consumers       126.00
              Tinplate packaging for firms           26.00
              Steel packaging                        26.00
GLASS         Glass packaging (non-deposit)          98.0
WOOD          FIN pallets (stamped 100 x 120 cm)     1.45
              EUR/EPAL pallets (stamped 80 x 120     1.45
              cm)
              Rental pallets                         1.45

                                                                                                               17
Other wooden pallets                        1.90
              Cable reels                                 1.45
              Other wooden packaging                      1.90
OTHER         Other packaging                             -

*) Value added tax is added to the fees.
**) Conventional plastic packaging refers to non-biodegradable plastic packaging, including bio-based plastic
packaging that is not biodegradable.

If a company is invoiced a material-specific recycling fee of more than EUR 10,000, RINKI will invoice it in two equal
instalments at the same time so that the second one is due four months after the first but not later than October 2020

Late declaration fee and estimate-based invoice for packaging data

According to the terms of contract, companies must report to RINKI Ltd annually the packaging materials and quantities
that they have used to pack their products and placed on the market or imported together with its products. The 2019
packaging data must be submitted by 29 February 2020.

Reporting the packaging data is essential for the producer responsibility system to work as it directly affects the system's
financing, invoicing and operations. If a company submits the 2019 data after 29 February 2020, RINKI Ltd will collect a
fee for the late declaration. The fee is EUR 200 (+VAT) for each delayed month or part thereof and it will be charged for
a maximum of three months

If the company has not submitted the 2019 packaging data by the end of May 2020, RINKI Ltd will invoice the late
declaration fee as well as estimate-based customer and recycling fees, which will be based on the packaging data
available to RINKI Ltd.

                                                                                                                         18
10. Greece: HE.R.R.Co.
Monetary contributions for 2020

                                  Contributions € cents per unit

  Fixed contribution                                                     0.04

                                Contribution by weight (€/tonne)

  Cardboard & paper                                                     52.50

  Paper cartons for liquids                                             57.00

  Plastics                                                              66.00

  Aluminium                                                              8.80

  Metal                                                                 21.00

  Glass                                                                 10.90

  Wood                                                                   9.50

  Other                                                                 66.00
*The above prices do not include VAT

Financial contribution calculation rules

1. All the material constituting the manager’s consumption packaging is charged based on the weight depending on
the price of their material according to the monetary contribution tables hereof (contribution by weight). The
consumption packaging articles are charged as a total with one more fixed contribution according to the monetary
contributions tables (Annex B1) hereof (fixed contribution).

2. All the material constituting the other packages is charged by weight based on the price of their material
according to the monetary contributions tables hereof (fixed contribution). Every component per unit of other
packaging is charged with one more fixed contribution according to the monetary contribution table hereof (fixed
contribution).

3. The glues, the adhesive tapes, the tax tapes, the metal connections that are part of a packaging (e.g. a carton) and
the user booklets or manuals are not considered packaging components.

4. The total contribution of a packaging is the aggregate of the contributions by weight of the material that
constitute all packaging (consumption & other packaging) plus the proportionate fixed contributions by applying
the previous rules.

                                                                                                                     19
11. Hungary: ÖKO-Pannon

According to the legislations in Hungary all companies are obliged to pay an environmental tax (official name:
environmental product charge) to the National Tax and Customs Administration (abbreviated Hungarian name: NAV).

The object of the charge is the packaging material instead of the packaging and therefore packers are directly not
subject of the law for domestic products.

In case of products produced abroad the importer company is responsible for the charge, i.e. the company who imports,
and sells the product in Hungary at the first time (with the first HU-VAT Nr. invoice), or uses it for their own purposes.

Green Dot trademark - Isolated use of the Green Dot trademark

Our company provides the legal usage of Green Dot trademark for producers, importers and retailers as well.

We offer 2 types of contract:

  1. If the company has little amounts of packaging, it is reasonable to choose a simplified contract. In this case
  the Licensee shall send the Licensor a packaging emission report once a year and pay 0.5 HUF/kg by the
  amount of the packaging emission.

  2. The normal contract provides possibility to choose from 2 types of payment:

      •   0.5 HUF/kg by the amount of the packaging emission quarterly.
      •   according to categories presented in the following chart:

      Annual amount of the packaging
                                                        Annual fee            Packaging category
                emission
  above 10,000,000 kg                             HUF 3,000,000              A

  between 5,000,000 – 10,000,000 kg               HUF 2,000,000              B

  between 3,000,000 – 4,999,999 kg                HUF 1,000,000              C

  between 1,000,000 – 2,999,999 kg                HUF 500,000                D

Services of ÖKO-Pannon

Consultancy service

Due to a legislation of environmental product charge put into force in January 2012, ÖKO-Pannon Plc. has
launched consultancy service on compliance with actual environmental product charge and waste law for
packaging emitters.

                                                                                                                        20
•   Notification obligation
•   Environmental product charge declaration
•   Environmental product charge refund process
•   Providing the use of Green Dot trademark
•   Optimization consultancy with relation to products liable to product charge (packaging, WEE – electric and
    electronic waste, battery, tyre, advertisement paper) including:
        o interpretation and use of laws in force regulating product charge with consideration to the
            company’s range of products
        o classification of packaging materials
        o creating the system of taking over the liabilities
        o forming the textual content of invoices (incoming, outgoing)
        o classification of product packaging into the proper product charge category
        o updating background administration in accordance with new laws
        o preparing reports to NAV (National Tax and Customs Administration)
        o review of NAV reports both in terms of running year and previous years
        o continuous availability
        o on-site consultancy
        o petition of stance from NAV
•   Consultancy on individual exemption and coordination
•   Preparing for compliance with the actual law on waste management
•   Preparing for compliance with the packaging regulation
•   Supervision related to the fulfilment of recovery and recycling obligation and product charge reports
•   Consultancy in the field of fulfilment of international recovery and recycling obligation (sending in
    contracts and reports)
•   Packaging or not packaging – providing professional opinion according to the laws in force

                                                                                                            21
12. Italy: CONAI

Environmental Contribution for Packaging – 2020

               Material                           Compliance cost (EUR/tonne)
                                             3,00 €/t
 Steel
                                             15,00 €/t
 Aluminium
                                             35,00 €/t
                                             55,00 €/t for poly-laminated packaging
 Paper                                       with a prevalence of carton suitable for
                                             containing liquids

                                             9,00 €/ton
 Wood
                                             Level A: 150,00 €/t

                                             Level B1: 208,00 €/t

 Plastic
                                             Level B2: 436,00 €/t

                                             Level C: 546,00 €/t

                                             27,00 €/t
 Glass

Full details link: http://www.conai.org/en/businesses/environmental-contribution/

                                                                                        22
13. Israel: TAMIR
Financial contribution tariff per material 2020:

                                             NIS per tonne   NIS per tonne
            Material
                                              household       commercial

  Glass                                            280              40

  Cardboard &Paper                                 178             139

  Drinking Carton                                  210              40

  PET                                              423              84

  HDPE                                             448              84

  LDPE                                             474              84

  PP                                               584              84

  PS                                               782              84

  Other plastic/material                           782              84

  Metal                                            210              55

  Wood                                              31              31

1 Euro=4 NIS

                                                                             23
14. Luxembourg: Valorlux

                     Material                        Compliance contribution 2020 (EUR/kg.)

 Glass (bottles and jars)
                                                                  0,0137
 Paper / cardboard
                                                                  0,0441
 Steel
                                                                  0,0206
 Aluminium
                                                                  0,0246
 PET bottles
                                                                  0,3245
 HDPE bottles
                                                                  0,2397
 Beverage cartons
                                                                  0,3055
 Other recoverable products
                                                                  0,6297
 Other non-recoverable products
                                                                  0,7186

Contribution for commercial packaging in 2020 €/kg HTVA

The fees for the commercial packaging remain unchanged.
Commercial Paper/Cardboard 0,0145
Commercial Wood 0,0145
Commercial Others 0,0395

                                                                                              24
15. Republic of North Macedonia: PAKOMAK d.o.o
The compliance costs for the companies responsible in Macedonia are presented in the table below:

                     Compliance Contributions 2019                            in EUR/tonne

                              Packaging Material

                     1            Paper/cardboard                                 18.75

                     2            Plastics                                        22.76

                     3            Glass                                           20.39

                     4            Metal                                           21.42

                     5            Composite materials                             22.66

                     6            Wood                                            21.84

      *1 EUR = 61,6 denars.

      * Fees are calculated without 5% VAT .

      In case of devaluation, PAKOMAK DOO reserves the right for adequate correction of the exchange rate of
      EURO.

      es for obligated companies in Macedonia Green Dot fees 2019 in EUR/ton Type of packaging waste 1
      Paper/Cardboard 2.53 2 Plastic 4.88 3 Glass 1.83 4 Metal 3.45 5 Aluminium 3.45 6 Composite materials 5.36 7
      Wood 1.63 1 EUR = 61,6 denars. * Fees are calculated without 5% VAT

                                                                                                                    25
16. Malta: GreenPak

The membership Compliance Costs for the year 2020 are presented below:

                  Material                        iFees €/metric tonne

               Plastics                                    67,95
packaging
Transport

               Paper/Cardboard
 Store &

                                                           67,95
                                                           61.20
               Metals       61.20 27.00
                                                           27.00
               Wood                                        65,70
               Other                                       72,00
               Plastics                                   99,00
               Paper and Cardboard                        75,60
 Consumer
Packaging

               Glass                                      110,00
                                                          106.00
               Metals       106.00 58.50
                                                           58.50
               Wood                                       73,80
               Other                                      135,00

            *Fees are excluding VAT and are calculated to the nearest 100kgs (0.1 metric ton)

Notes:

a)   Fee is calculated to the nearest 100kgs (0.1 metric tonnes).
b)   Fees are applicable from 1st January 2020.
c)   Above fees are exclusive of VAT.
d)   Minimum charge is €150 (incl. ERA registration + VAT).

Payment Terms
Yearly Participation Fee excl VAT          Payment terms
€ 150 to € 2,500                           On invoice
€ 2,501 to € 12,000                        50% on invoice, 50% by 1st July
€ 12,001 to € 46,000                       4 pro-rata quarterly payments due 1st week
                                           of each quarter.
€ 46,001 and over                          12 pro-rata monthly payments due 1st week
                                           of each month.

More information on the Payment Terms you can find here:

                                                                                                26
17. The Netherlands: Afvalfonds Verpakkingen

The following companies are responsible for registering and contributing to the system:

Regular producer/importers of packed products

This is the first Dutch company who:
1°. places substances, preparations or other products on the market in a packaging; and/or
2°. commercially imports substances, preparations or other products in a packaging and disposes of the packaging;
and/or
3°. commercially instructs another to provide the packaging of substances, preparations or other products with its name,
logo or brand; and/or
4°. places a packaging on the market which is intended to be added to substances, added to substances,
preparations or other products to be provided to the user;

Foreign distance sellers (e.g. online sales)
Foreign companies that fulfil the functions as described above, but do so by selling directly to a private consumer (i.e.
not to a company). In cases where foreign companies sell packed products to Dutch companies, the Dutch company is
seen as the obliged company.

The packaging waste management compliance costs in 2020 are listed below:
Material                                                                   Fee 2019 (€/kg) ex. VAT

Glass                                                                      0.0560

Paper/Cardboard                                                            0.0220

Plastics (including biodegradable plastics)                                0.6000

Plastics, differentiated fee (only upon request)                           0.3400 *

Aluminium                                                                  0.0500

Other metals                                                               0.0800

Wood                                                                       0.0200

Other materials                                                            0.0200

                                                                                                                            27
General fee (company can’t or doesn’t want to specify the material)         0.7700

Beverage cartons                                                            0.3800

Bottles in a deposit system                                                 0,0200

Plastic bottles > 0.75 l that do not take part in the mandatory deposit
                                                                            € 0.25 per bottle
scheme

The fees are calculated based on the principle of activity-based costing. This means that the most
recent historical costs of expenses of collection and sorting of packaging waste, including the
management of the organisation, are taken into account.

Lower fees for certain commercial/industrial packaging
Companies who are mainly active in a b2b-environment may be entitled to apply lower fees. Please contact us at
info@afvalfondsverpakkingen.nl for the possibilities.

Differentiated / modulated fee
There is a modulated fee for rigid plastics that are recyclable and that have a positive market value at the point of sale to
the recycler. The fee can only be applied upon request and is liable to the evaluation of Afvalfonds Verpakkingen. In the
process of evaluation, the Recycle Check, developed by Kennisinstituut Duurzaam Verpakken, will be used. More
information about the differentiated fee can be found (in Dutch) on
https://afvalfondsverpakkingen.nl/verpakkingen/gedifferentieerd-tarief.

Composite packaging
Composite packaging is packaging that consists of several, non-separable types of materials (for example laminates).

The obliged company must pay the Packaging Waste Management Contribution on the various types of material of
which the composite packaging consists and declare these material types separately on the Provisional Statement and
Declaration.

Packaging components
Packaging components and ancillary elements integrated into packaging shall be considered to be part of the packaging
into which they are integrated. Ancillary elements hung directly on, or attached to, a product and which perform a
packaging function shall be considered to be packaging unless they are an integral part of this product and all elements
are intended to be consumed or disposed of together.

Reporting threshold
Only companies that place 50,000 kg or more on the Dutch market in a calendar year are obliged to register and pay the
according packaging fees. For the first 50,000 kg, companies are not invoiced. Please be aware that companies should
provide documented proof that they place less than 50,000 kg of packaging on the Dutch market, if they claim so.

For companies that place less than 50,000 kg packaging on the Dutch market, Afvalfonds Verpakkingen investigates the
weight of “packaging on the market” by means of market research.

Financing
The financing of EPR for packaging in the Netherlands is executed by Afvalfonds Verpakkingen, who
is responsible for the organization and reaching recycling targets and who delegates certain
operational tasks to Nedvang. Because of a binding agreement between Afvalfonds Verpakkingen

                                                                                                                          28
and the vast majority of obliged companies, all obliged companies with more than 50.000 kg of
packaging put on the market have to register with Afvalfonds Verpakkingen and pay for the
organization of EPR for packaging. This payment is called the packaging waste management
contribution.
All packaging, including packaging from companies and industry, is included in the Dutch EPR
scheme.

The budget is spent on the following items:
• Control of the companies’ declarations of packaging on the market
• Identification of additional customers / free riders
• Estimate of the weight of packaging put on the market by companies that put less than 50.000 kg.
per year on the market on an individual basis
• Estimate of the weight of transport packaging put on the market
• Cooperation with municipalities and waste management companies to gather data on collection
and recycling of packaging waste
• Communication to enhance the collection and recycling of packaging waste
• Calculation and reporting of recycling rates
• Logistics, sorting and sale of plastic packaging waste from households
• Structural contribution to a clean and litter free environment
• Financing of an independent and neutral organization to gather knowledge on packaging waste
management and sustainability.

                                                                                                     29
18. Norway: Grønt Punkt
LICENSE FEES FROM GR0NT PUNKT NORGE AS FOR 2020
Changes in bold print Prices in NOK
Plastic Packaging                                              01.01.2020            01.02.2020
Plastic film with producer payment                             0,50 kr per kg        0,50 kr per kg
Expanded plastic (Airpop, EPS, EPX etc.)                       2,20 kr per kg        2,20 kr per kg
Industrial packaging:
Hard plastic and packaging for chemicals and
hazardous substanses                                           1,36 kr per kg        1,82 kr per kg
Polypropene (bag and liner)                                    0,84 kr per kg        1,13 kr per kg
Silage film , clear polyethylene film with thickness of 70
^ (mu)                                                         2,43 kr per kg        1,56 kr per kg
Other agricultural films (mulch, nonwovens and nets)           4,00 kr per kg        4,00 kr per kg
Household packaging (f.pak) and service packaging:
Film                                                           1,38 kr per kg        1,85 kr per kg
Hard plastic, packaging for chemicals and hazardous
substanses and polypropene bag                                  1,38   kr per kg     1,85   kr per kg
Other service packaging                                         1,38   kr per kg     1,85   kr per kg
Gardening and agricultural packaging                            1,38   kr per kg     1,85   kr per kg
Carrier bags under 10 liter                                  0,0138    kr each     0,0185   kr each
Carrier bags over 10 liter                                   0,0253    kr each     0,0339   kr each
Packaging with environmental tax:
Film, e.g. stand-up pouches, bag in box, bottles               1,38 kr per kg        1,85 kr per kg

Fibre based Packaging

Cardboard packaging base weight > 150 gr/m2                    0,29 kr per kg        0,29 kr per kg
Moulded fibre packaging for eggs etc.                          0,29 kr per kg        0,29 kr per kg

All Liquid board packaging containers                         0,030 kr each         0,030 kr each

Corrugated board and solid board > 600 gr/m2                   0,05 kr per kg        0,05 kr per kg

Glass Packaging containers

Packaging without environment tax
Volume 0 - 250 ml                                             0,099 kr each         0,099 kr each
Volume 251 - 500 ml                                           0,198 kr each         0,198 kr each
Volume over 500 ml                                            0,296 kr each         0,296 kr each
Packaging with environment tax
Volume 0 - 250 ml                                             0,138 kr each         0,138 kr each
Volume 251 - 500 ml                                           0,276 kr each         0,276 kr each
Volume over 500 ml                                            0,413 kr each         0,413 kr each

Metal Packaging containers

                                                                                                        30
Volume 0 - 250 ml can/tin                               0,058   kr each    0,055   kr each
Volume 251 - 500 ml can/tin                             0,130   kr each    0,124   kr each
Volume over 500 ml can/tin                              0,219   kr each    0,208   kr each
Tubes                                                   0,064   kr each    0,061   kr each
Table serving item                                      0,016   kr each    0,015   kr each
Aluminiumform 0 - 500 ml                                0,064   kr each    0,061   kr each
Aluminiumform > 500 ml                                  0,143   kr each    0,136   kr each
Lids                                                    0,011   kr each    0,010   kr each
Crown cork                                              0,004   kr each    0,004   kr each
Packaging with environment tax
Volume 0-250 ml                                         0,058 kr each      0,055 kr each
Volume 251 - 500 ml                                     0,130 kr each      0,124 kr each
Volume over 500 ml                                      0,219 kr each      0,208 kr each
Hazardous waste
Hazardous contents 0 - 1,0 liter                        0,281   kr each    0,267   kr each
Hazardous contents 1,0 - 9,9 litres                     0,732   kr each    0,695   kr each
Hazardous contents 10 litres                            1,591   kr each    1,511   kr each
Hazardous contents > 10 litres                          3,379   kr each    3,210   kr each

 Members with packaging use corresponding to up to NOK 5.000 per year
 pay a fixed annual amount of
 NOK 3.000 without reporting packaging amounts. VAT is added to all
 license fees.
Financing

The costs of running the collection and recovery schemes are covered by the compliance costs paid by Green Dot
Norway's members, which depends on the pro rata consumption declared per period. The fee is then distributed to
the five material companies. Depending on the member companies’ packaging use, they submit a form to Grønt
Punkt Norge six, four or once a year.

Green Dot Norway is a non-profit organisation owned by five material companies.

About the figures:

       •   VAT not included;
       •   EUR 1 = NOK 10.54 (2020)
       •   NOK 1 = 100 øre

                                                                                                             31
19. Romania: ECO-ROM AMBALAJE

Recycling and Recovery Fees 2020

The national legislation transposing the European Directive for Packaging and Packaging Waste stipulates that the
recovery and recycling objectives pertain to the entire quantity of packaging placed on the market by the obliged industry,
regardless of the waste stream (i.e. household/municipal or the industrial-commercial sector), for which distinct targets
are yet to be set.

However, as of January 2019 the EPR schemes (PROs) have to calculate and publicly disclose distinct fees for the obliged
industry for the primary packaging, on one hand, and secondary and tertiary packaging, on the other hand. The quantities
declared to PROs are exclusively based on the monthly declaration of the obliged industry related to packaging placed on
the market during the previous month.

For the packaging waste generated in the household/municipal waste stream, PROs are obliged to cover the net costs
incurred by delegated operators (municipal or private) related to separate collection, transfer, sorting and recovery (if
recycling is not possible), while the industrial-commercial waste stream is still market-driven by the demand-supply
mechanism.

                                                             Rate in euro/ton* for            Rate in euro/ton* for
                        Type of material                     industrial-commercial            household/municipal
                                                                   packaging                        packaging
                              Glass                                     99                               115
                                        PET                            147                               164
                                         PE                            105                               115
                                        PVC                            105                               115
              Plastic
                                         PP                            105                               115
                                         PS                            105                               115
                                       Other                           105                               115
                        Paper-cardboard                                 84                               94
                              Steel                                     89                               94
                           Aluminium                                   147                               173
                             Wood                                       89                               94
*prices do not include VAT and were calculated for an average currency exchange rate of 4.775 lei/euro

                                                                                                                        32
20. Slovakia: ENVI-PAK
The price for ENVI-PAK´s compliance costs are based on t h e weight and material type of packaging. The
materials are separated in 10 types:

   •   Glass
   •   Plastics PET
   •   Other plastics besides PET
   •   Paper / Cardboard
   •   Composite beverage carton
   •   Miscellaneous composites
   •   Metals aluminium
   •   Metals steel
   •   Wood
   •   Other packaging materials

In determining the fee, the packaging must first be separated into all its parts, sorted by fractions. The weight,
multiplied by the price for each material is the fee for the participation in our packaging recovery system. Prices
can be ordered upon request. Interested companies can order an offer via the customer portal.

There is no payment connected with the registration into the ENVI-PAK system.

                                                                                                                 33
21. Slovenia: Slopak

PACKAGING FEES 2020

               PACKAGING MATERIALS                            PACKAGING FEE
                                                        EUR/tonne (VAT not included)
GLASS
Glass                                                               19,00
PAPER
Paper Sales                                                         17,00
Paper Group and transport                                           17,00
PLASTICS
Plastics Sales                                                      249,00
Plastics Sales PET                                                  185,00
Plastics Group and transport                                        249,00
Plastics PVC                                                        249,00
METAL
Metal Aluminium                                                     175,00
Metal Steel                                                         219,00
WOOD
Wood                                                                39,00
OTHER MATERIALS
Other materials Textile, Straw                                      249,00
Other materials Non-recyclable                                      249,00
COMPOSED MATERIALS
Composed materials with predominant paper                           17,00
Composed materials with predominant plastic                         249,00
Multi-layered beverage carton                                        9,00

Hazardous waste packaging 1                                         650,00
1 Packaging contaminated with hazardous substances according to the legislation on
chemicals and is marked as hazardous with security sheet for removal.

Minimum amount of the packaging fee is 100 EUR (VAT not included) per year.

The licence fee for the use of the trademark “The Green Dot” is already included in the packaging fee.

                                                                                                         34
22. Spain: ECOEMBALAJES ESPAÑA, S.A. (ECOEMBES)
Green Dot fees - Ecoembes

The fees in effect were calculated to cover the cost involved in the selective pick-up of packaging waste and
updated to account for the increasing number of people that are covered by the Selective Pick-up System.

The cost of the Green Dot applicable to packaging depends on the type of material, meaning that for a given
weight, aluminum packaging will not cost the same as packaging made of cardboard, plastic or steel.

The fees for the different packaging materials are as follows:

                                                                                                                35
Simplified Declaration Fees

The fees applicable to this category are determined based on the tons of packaging marketed in the previous year.

For additional information, click here

                                                                                                                    36
23. Spain: ECOVIDRIO (Glass packaging)

Regarding glass packaging, green dot fee is composed of two pats:

    •   One for packaging units placed on the market and
    •   the other for the weight of those glass packages.

Therefore, there will be one contribution in € per packaging unit plus a contribution in € per Kg. of packaging.

In monetary terms, this frame is also a way to promote ecodesign and prevention, as heavy packaging or a high number
of units of packaging must pay a higher fee.

2020 Green Dot fee = C1 x units of glass containers + C2 x kg of glass containers
C1= 0,00348 €/unit
C2 = 0,02451 €/kg

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24. Sweden: FTI

                                                   Packaging fees
                                                            From April 1, 2019            From January 1, 2020
                          Item no.       Material
                                                                (SEK/kg)                        (SEK/kg)

                            310      Paper (high)                  1.92                            3.28

                            315      Paper (low)                    na                             2.23

                            410      Plastic (high)                3.90                            5.22
 Household packaging
                            415      Plastic (low)                 3.15                            3.47

                            511      Aluminium                     2.00                            2.21

                            512      Steel plate                   3.15                            3.59

                            320      Paper                         0.01                            0.01

                            420      Plastic                       0.03                            0.03

      Commercial            521      Aluminium                     0.01                            0.01
       packaging            522      Steel plate                   0.16                            0.16

                            523      Barrels                       0.04                            0.04

                            524      Steel plate, wire             0.28                            0.28

                            330      Paper (high)                  1.73                            2.63

                            335      Paper (low)                    na                             1.79

   Service packaging        430      Plastic (high)                3.51                            4.18

                            435      Plastic (low)                 2.84                            2.78

                            531      Aluminium                     1.80                            1.77

More information is found here: https://www.ftiab.se/2934.html

Note – a new fee structure for paper packaging is implemented January 1, 2020. All new fees are due from January 1,
2020.

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