The Association of Metal Packaging (VMV) has called for a stronger alignment of participation fees with actual recycling costs as part of a hearing on the Packaging Act Implementation Act in the Bundestag. According to the association, metal packaging is currently financially supporting other material fractions within the dual systems.
The association argues that steel and aluminium metal packaging is particularly cost-effective to recycle due to its high recyclability and the revenue generated from the sale of secondary raw materials. Nevertheless, largely uniform participation fees have become established within the dual systems, which do not sufficiently take into account the different costs of collection, sorting, and recycling. According to VMV, the tinplate fraction finances the recycling of certain plastic packaging with an annual sum of 60 to 80 million euros.
Association proposes new cost distribution
In the VMV's view, the existing distortion of competition cannot be resolved solely through the eco-modulation provided for in the European Packaging and Packaging Waste Regulation (PPWR). Instead, the association calls for a distribution of disposal costs between the different packaging materials that is based on the polluter pays principle. The costs for collection, sorting, and recovery should be more closely aligned with the actual expenses and the revenues generated by the respective material fractions.
The VMV suggests providing for a corresponding legal ordinance in the Packaging Act Implementation Act. The aim is greater cost fairness between different packaging materials, without causing additional burdens for consumers or the overall system.
Criticism of regulations for industrial packaging
In addition, the association has concerns regarding individual regulations for industrial and commercial packaging. The planned financing of the Central Agency for Packaging Register (ZSVR) by producer responsibility organisations and producers of packaging not subject to system participation is viewed critically. In the VMV's opinion, this model could be problematic in terms of fiscal constitutional law and should be fundamentally revised.
Furthermore, the association warns against an expansion of the scope of packaging subject to system participation. In the VMV's assessment, the planned definitions could lead to additional transport packaging and packaging not previously subject to system participation being included in the financing of the dual systems. This could have significant economic burdens for the manufacturers concerned.
Source: Statement by the German Association of Metal Packaging Manufacturers (VMV)
