The draft bill for the Packaging Law Implementation Act (VerpackDG) has been widely criticised by leading associations in the packaging and recycling industry.
The German Paper Industry Association, the BDE Federal Association of the German Waste, Water and Recycling Industry and the BVSE Federal Association for Secondary Raw Materials and Waste Disposal are unanimous in warning of rising costs, additional bureaucracy and national overfulfilment of the EU Packaging Ordinance (PPWR).
In the Centre of criticism is the planned establishment of a new organisation for reduction and prevention measures. According to the associations, it would cause additional annual costs of around 90 million euros - even for packaging areas in which functioning take-back and recycling structures already exist. No additional benefits for waste prevention or recycling are recognisable.
In addition, the associations criticise the expansion of the funding scope of the Central Agency Packaging Register and new obligations for commercial and industrial packaging. These regulations go beyond the requirements of the PPWR and are an example of so-called gold plating. At the same time, the BDE and BVSE see a risk that inadequate transitional regulations will undermine the cost stability of existing systems.
SMEs at risk
A particularly clear warning from the BVSE against structural market distortions to the detriment of medium-sized disposal and recycling companies. The planned regulations for commercial packaging could weaken proven decentralised structures and promote market concentration in favour of a few large providers - although the PPWR does not require free take-back for this packaging.
The three associations are therefore calling for a consistent 1:1 implementation of the PPWR without special national approaches. What is needed is a practicable legal framework that strengthens existing cycles, enables investment and ensures competitiveness - instead of burdening functioning structures with additional bureaucracy and costs.
The Trade association for carton packaging for liquid foods (FKN) warned against over-regulation by the current draft bill on the national implementation of the EU Packaging Ordinance (PPWR).
Sources: The paper industry, BDE, BVSE
