The German Confederation of Skilled Crafts (ZDH) is calling for changes to the extended producer responsibility under the EU Packaging and Packaging Waste Regulation (PPWR). The catalyst was the end of the consultation period for the corresponding implementing act on 10 September.
According to the ZDH, the PPWR does not make a sufficient distinction between producers and manufacturers regarding extended producer responsibility (EPR). This could lead to, for example, Bakeries for bread roll bags, cake packaging or coffee cups have to assume obligations, even though they do not manufacture these packaging materials themselves, but use them for the sale of their products.
„The aim of the regulation to reduce packaging waste is correct. However, the problem is that extended producer responsibility (EPR) does not properly distinguish between producers and manufacturers, explains ZDH Secretary General Holger Schwannecke.
ZDH calls for de minimis thresholds
The association is calling on the European Commission to make the rules more practical and proportionate. This should include effective de minimis thresholds below which businesses are exempt from EPR obligations. In addition, companies should be able to report their supplies to other EU member states to national systems. The latter could then transfer the data to a uniform European reporting portal.
In the opinion of the ZDH, the appointment of an authorised representative should also remain voluntary. The association also criticises the reporting and registration obligations associated with the EPR. Costs and bureaucratic effort could be significant, particularly for micro-enterprises, small businesses and craft trades in border regions.
Schwannecke therefore calls for the draft implementing act not to be adopted as long as there is no legal certainty regarding extended producer responsibility.
Source: Central Association of German Crafts
