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1. December 2023

Making packaging sustainable

The legal requirements for packaging are becoming stricter. What companies should do now to avoid additional costs in the future.

Industry experts agree: the legal requirements for packaging will soon become much stricter. This is because not only the EU, but also the German government has ambitious targets for promoting the sustainability of packaging. The Federal Ministry for the Environment has not yet presented a concrete draft for the planned amendment to Section 21 of the German Packaging Act (VerpackG) on the ecological organisation of participation fees for packaging. And it could still be a few months before the EU packaging regulation (PPWR) is adopted. However, Stefan Munz, Head of Innovation and Sustainability at EKO-PUNKT, is convinced: “The relevant regulations will come, it’s only a matter of time.” He therefore advises companies to make their packaging fit for the future now in order to avoid additional costs in the future.

In its coalition agreement, the German government has formulated ambitious goals for improving the sustainability of packaging: “We will reward resource-conserving and recycling-friendly packaging design and the use of recyclates with a legally enshrined fund model. We are introducing a recycling label,” the paper states. “These are two sentences that really pack a punch,” commented Stefan Munz, Head of Innovation and Sustainability at EKO-PUNKT, REMONDIS’ Dual System. For, even if a concrete draft for the amendment to § 21 VerpackG is still a long way off, the coalition agreement clearly shows where the journey is heading: “An ecological organisation of the participation fees for packaging with a fund model is coming! Especially as the objectives of the amendment to the German Packaging Act are largely in line with the draft of the EU packaging regulation PPWR, which even sets out specific requirements for the use of recyclates.”

Stefan Munz, Head of Innovation and Sustainability at EKO-PUNKT

High demands on the use of recyclates and recyclability

According to the current draft of the EU Packaging Regulation, plastic packaging should consist of at least 10 to 35 per cent post-consumer recyclates from 2030, depending on the type of packaging, and from 2040 the proportion should already be 50 to 65 per cent. In future, companies will be required to provide proof of the proportion of recyclate by means of a so-called declaration of conformity in the technical information on the packaging.

The draft also sets out specific requirements for recyclability: By 2027, “design for recycling” requirements are to be defined for 30 packaging categories and packaging is to be categorised into five recycling classes depending on its degree of recyclability. Packaging in recycling class E, which is less than 70 per cent recyclable, is to be banned from 2030. In addition, the participation fees for packaging are to be staggered depending on recycling performance.

Act now and make the packaging range fit for the future

“Even if the vote on the draft EU Packaging Regulation in the trialogue process between the EU Parliament, the EU Environment Council and the EU Commission is still ongoing, industry experts agree that a fund will be introduced,” explains Munz. “The basis will be a self-assessment by the companies. They must know the degree of recyclability of each of their packaging in order to be able to submit legally compliant reports. Companies whose packaging falls below a certain recyclability threshold will have to pay penalties to the fund, known as the eco-modulation fee.”

According to Munz, in order to avoid this, distributors of packaging should take stock of their product range today and use this as a basis for defining targets for its optimisation. The following questions need to be answered:

  1. How recyclable is the packaging?
  2. What additional costs can be expected in the future?
  3. How can packaging be saved?
  4. How can the recyclability of packaging be improved?
  5. How can recyclates be used?

Support from EKO-PUNKT – the centre of excellence for packaging

EKO-PUNKT can help companies find the answers to these questions. As a centre of excellence for packaging, REMONDIS’ Dual System offers to check the recyclability of packaging based on the minimum standards of the Central Agency Packaging Register (ZVSR), either in the laboratory or online using the PackLab tool. The costs of a future eco-modulation fee can also be simulated using an integrated fund calculator. On request, EKO-PUNKT can also make specific suggestions for recyclates or alternative materials that can be used to improve the eco-balance of packaging and also provide information on possible material savings.

Once the recyclability has been checked, EKO-PUNKT issues a certificate for the customer’s records. In future, companies can use this as a basis for the upcoming self-assessment under the EU Packaging Ordinance or to claim financial support in accordance with Section 21 of the Packaging Act.

“Companies should start preparing today for the upcoming tightening of legal requirements. Because if you don’t act now, you may pay more in the future.”

Stefan Munz, Head of Innovation and Sustainability at EKO-PUNKT

Image credits: image 1: iStock – 97; image 2: REMONDIS


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