One month remains before the Special Tax on Non-Reusable Plastic Containers takes effect, and the supply chain isn’t ready to operate smoothly. Experts warn there is persistent uncertainty due to numerous technical questions. The primary issue is the absence of clear legislation that defines who pays the tax and how goods should be declared at customs. Administrative costs may rise as firms adapt, leading to higher consumer prices. The tax is described as highly intricate, with some observers predicting enforcement challenges and limited control capacity.
Industry leaders note that manufacturers are allowed to pass the tax onto their customers. In later stages of distribution, invoices or certificates may be presented separately if the buyer requests them, though the decision may depend on a company’s competitive stance and policy. In this view, flexibility exists but varies by business model.
Officials emphasize that adapting administrative processes, registrations, and certification routines will add costs. Projections estimate that updating computer systems and redefining logistics could require hundreds of millions of euros. Government officials expect the tax to generate annual revenue in the hundreds of millions, while industry voices frame it as an additional cost embedded in the final price of products.
Under the current framework, non-reusable plastic products carry a tax of 0.45 euros per kilogram. The packaging’s origin and the exact quantity must be verified for each purchase or import, regardless of the supplier’s country. In the first year, manufacturers can rely on a self-declaration to show how much recycled material is used in their products.
There are concerns about how goods will pass through customs and how declarations will be managed for future imports. Companies worry about a lack of robust product certification and the risk that the tax could distort competition. The scope of the measure covers all forms of packaging, creating broad implications for the entire value chain.
Delays not currently on the table
Across Europe, Spain appears unique in pressing ahead with this design, while Italy delayed the measure until 2024 and Portugal rolled it out in stages. Associations highlight the technical complexity and urge government postponement to avoid harming competitiveness or consumer costs. Several industry groups have written to ministries explaining why a delay could be beneficial, though this request has not yet altered the timetable.
Even with these appeals, postponement is unlikely because the rate requires parliamentary approval and forms part of commitments with the European Commission tied to Recovery funds. Observers argue that the policy should be calibrated to minimize disruption while advancing environmental goals.
Other regions and nations, including Germany and the United States, are pursuing similar measures to boost circular economies. Some participants note that higher recycling rates in these areas should inform European timing decisions, underscoring concerns about competitiveness and the pace of economic recovery. Consequently, calls persist to reconsider the effective date and to implement safeguards that protect both businesses and consumers.
As the debate continues, the industry remains focused on practical steps to ensure a smoother transition, from data collection to system integration. The overarching aim is to align environmental objectives with market realities, avoiding abrupt price shifts while expanding recycling and reusability across packaging types.
• Related developments