The Packaging Transition initiative has strongly criticised a study by GVM and ifeu on municipal packaging taxes. In a fact check, the initiative takes issue with, among other things, the data basis, the assessment of reusable packaging, and the study's ecological and economic analysis.
Commissioned by eight associations representing the single-use packaging, retail, and hospitality sectors, the Gesellschaft für Verpackungsmarktforschung (GVM) and the Heidelberg Institute for Energy and Environmental Research (ifeu) examined the impacts of municipal packaging taxes. According to the initiative, GVM and ifeu conclude that the tax is an inefficient regulatory instrument with limited effectiveness. The fact check contradicts this assessment, citing five central points of criticism.
Criticism of database and evaluation scale
According to the initiative, the data basis of the study is not sufficiently transparent in key areas. While it is based, among other things, on interviews and on-site research in Tübingen and Freiburg, details regarding the interviews, survey methods and individual calculation steps are not accessible. Criticism is directed in particular at assumptions concerning potential shifts in customer behaviour away from the hospitality industry towards retail food stores.
Furthermore, the initiative criticises the scale used to evaluate the impact of municipal packaging taxes. The study calculates with a hypothetical nationwide introduction and puts potential savings in waste and CO2 emissions into relation with national total figures. From the initiative's perspective, a municipal tax must instead be assessed primarily on the basis of its local impact.
As examples, the fact check names Tübingen and Konstanz. In a survey in Tübingen, 73 percent of businesses reportedly stated that they had reduced their single-use consumption since 2019. Accordingly, 17 percent now completely dispense with single-use packaging. For Konstanz, the initiative refers to a reduction in the volume of waste in public spaces of around 22 tonnes following the introduction of the tax in 2025. The city derives a 30 to 50 percent reduction in packaging waste from this.
Initiative sees reusable packaging disadvantaged
Another point of criticism concerns the assessment of reusable packaging. According to the initiative, the study treats reusable packaging as a substitute for single-use packaging and thus counts it towards the total volume of packaging. As a result, the reduction effect achieved through repeated use is not adequately taken into account. Furthermore, so-called pseudo-reusable packaging is included in the overall evaluation of reusable systems.
As an indication of a steering effect of the tax, the fact check cites the development of existing reusable systems. In Constance, the number of Recup distribution points rose by nearly 40 per cent, and in Tübingen by almost 90 per cent. The use of Vytal containers in Tübingen almost doubled.
Critique of ecological and economic evaluation
The initiative also considers the ecological perspective to be too narrow. The assessment focuses essentially on greenhouse gas emissions. In the authors' opinion, resource and water consumption, land use, waste generation and littering, among other things, would also need to be taken into account.
Regarding the economic assessment, the fact check criticises in particular the focus on administrative costs. The initiative, on the other hand, points to revenue from the tax and potential municipal waste disposal costs. For Tübingen, it cites personnel costs of 100,000 euros for 2022, alongside revenues of one million euros. In Constance, according to information in the fact check, revenues would have reached around 1.2 million euros by 2025, with personnel costs of 60,000 euros.
Therefore, the initiative comes to a significantly different result than the study criticised by her. In their view, municipal packaging taxes are an effective lever for reducing single-use items and promoting reusable alternatives. The signatories of the fact check include BUND, Deutsche Umwelthilfe, Greenpeace, Mehrwegverband Deutschland, Recup, WWF and Zero Waste Germany, among others.
Source: Packaging Transition Initiative
