compliance teamThe allowance is pro rata, not a cliff
Step 1
Total the annual weight
Step 2
Apportion the allowance
Step 3
Charge only the excess
Step 4
Exclude deposit and single-use plastic
| Control | Evidence to retain |
|---|---|
| Scope | Entity, product, channel, stream and source |
| External action | Version, date, authorised filer and issued receipt |
| Maintenance | Source data, approval, invoice and next deadline |
What the text actually says
Article 2.3 of Annex 1 to the agreement states that no contribution is calculated over the kilograms below the limit, and that within those kilograms the various packaging materials carry the same weight share as in the total packaging weight.
In other words the free 50,000 kg carries the same material mix as the whole volume.
The arithmetic
Once the total passes 50,000 kg, the chargeable weight of a material is its own weight multiplied by one minus 50,000 divided by the total weight.
A producer at 85,000 kg therefore pays on 35,000 kg, split across materials in the same proportion as the original mix, rather than on the whole 85,000 kg.
Why the distinction matters
Most published summaries describe a cliff, which overstates the cost of crossing the line and can push a seller into decisions that are not in its interest.
The allowance does not apply to deposit or single-use plastic packaging, which is charged from the first unit.
Conclusion
Scope comes before a form. Connect the legal entity, product, sales channel and EPR stream to the rule that actually applies.
Evidence must remain traceable. Keep source data, versions, approvals, filings, receipts and every record issued by an external body.
Third-party decisions are never guaranteed. CONAI, public registers, collective systems and marketplaces control their own procedures, timing and decisions.