The Federal Environment Ministry headed by Minister Steffi Lemke has presented key points for revising the Packaging Act. The key points are not sufficient to make reusable packaging the standard, criticises Deutsche Umwelthilfe. The Federal Association of System Catering and the Industrial Association for Plastic Packaging have also criticised it.
The environmental and consumer protection organisation welcomes the desire to avoid waste and promote reusable packaging. One However, the obligation to offer reusable beverage bottles without a mandatory quota is not very effective, as well as for beverage and food packaging in the catering trade without disposable packaging. The DUH calls for a ban on single-use food for on-site consumption in the catering trade and the closure of a loophole for circumventing the current obligation to offer reusable food by using single-use cardboard or aluminium.
„It's good that Environment Minister Steffi Lemke has recognised that reusable packaging must be specifically promoted to bring about a packaging turnaround. However, the right measures must now be put in place. A reusable supply obligation for beverage bottles without binding targets offers barn door-sized loopholes for one-way discounters such as Aldi or Lidl in particular to circumvent the regulation. The most suitable solution would be a single-use levy of at least 20 cents in addition to the deposit on single-use plastic bottles and cans, as this would provide consumers with a financial incentive to switch to reusable packaging. Federal Environment Minister Steffi Lemke must improve her plans to revise the Packaging Act.“Barbara MetzDUH Federal Managing Director
According to DUH, the planned obligation to take back all reusable drinks bottles in shops will improve the return process for consumers. However, it must ensure that bottles returned to one-way discounters are returned to the reusable cycle for refilling as quickly as possible. A competition-driven delay or obstruction of the return of empty returnable bottles must be ruled out.
Test visits by DUH to implement the reusable packaging obligation that has been in force since January 2023 have shown that, in particular Fast-food chains such as McDonald's and Burger King have taken advantage of an exemption for disposable cardboard and aluminium tableware to be exempted from the reusable requirement have. However, switching from single-use plastic to cardboard is not environmentally friendly and does not result in a single gramme less waste. It is therefore a first step that the DUH demand to close this regulatory loophole should be implemented. The existing system in France, which has already been criticised by the DUH the ban on disposable food for on-site consumption in the catering trade is positive.
„The really large and particularly problematic amounts of waste are to-go packaging. As good as a ban on single-use packaging is for on-site consumption, the problem of discarded to-go packaging remains unaffected. Six months after the reusable packaging obligation came into force in the catering sector, it is clear that switching from single-use to reusable packaging does not work on a broad scale without a financial incentive. The municipal single-use tax that has been in force in Tübingen since the beginning of 2022 impressively demonstrates how successful this instrument is in promoting reusability. Since the introduction of the local single-use tax, the amount of waste in public spaces has visibly decreased and, in relation to the population, Tübingen has the most reusable catering establishments in Germany. Environment Minister Lemke must introduce such a levy on disposable crockery at federal level. Without this element, the reusable supply obligation will remain a toothless tiger despite the announced improvements.“
Thomas FischerDUH Head of Circular Economy
DUH welcomes the planned regulation against deceptive packaging with less content in the same packaging size. It is a suitable measure to curb consumer deception and the inefficient use of resources in times of high inflation.
The Bundesverband der Systemgastronomie e. V. (BdS - Federal Association of System Catering) has also criticised the planned reform and sees the difficulties for system catering.
„A general ban on single-use packaging does not take into account the questionable life cycle assessment of reusable packaging, the recyclability of paper packaging or aspects of food safety and hygiene. The complete switch to reusable alternatives would require an enormous organisational and financial effort for companies in the food service industry.“
Markus Sichert, BdS Managing Director
The IK supports the goals, the Reduce the amount of packaging regardless of the material and promote reusable packagingprovided that these are demonstrably ecologically favourable. Accordingly, the association is critical of the fact that the The obligation to offer reusable beverage packaging is not based on a current life cycle assessment will. The IK expressly welcomes the fact that the German government intends to amend Section 21 of the Packaging Act before the end of this legislative period with the aim of promoting the recyclability of packaging through financial incentive systems as a decisive step towards an efficient circular economy for packaging.
The association regrets that the legislator has not analysed the supposed ecological advantages of reusable packaging in the beverage sector in a current life cycle assessment - as repeatedly demanded by the industry - and that the Reusable packaging promotion also not linked to ecological requirements for packaging has. "Today's disposable bottles are recycled and do not need to shy away from ecological comparison with reusable bottles. Instead of a blanket promotion of reusable bottles, we would have considered it more expedient to promote the further ecological development of disposable and reusable containers," says Schmidt.
