The central packaging register LUCID has already been in operation for a good quarter of a year. When we were informed about the official starting signal we promised: „We will continue to monitor developments for our readers.“ It's time for a first interim assessment. It is cautiously optimistic.
In fact, the obligations arising from the Packaging Act for so-called First placer on the market of packaging and secondary packaging is nothing new. Since 1991, they have been required to report their packaging quantities in a Dual system and thus ensure their proper disposal or recycling.
151,000 companies are already registered
However, many companies apparently slipped through the cracks of the regulations of the then Packaging Ordinance as „free riders“. „The high number of enquiries from first-time distributors who don't know what product responsibility is has confirmed to us how necessary this measure and the Packaging Act are,“ said the head of the Central Agency Packaging Register (ZSVR), Gunda Rachut, on the official launch of LUCID.
Meanwhile LUCID about further growth. 151,000 companies are now registered, the ZSVR announced at the beginning of March when asked. That is over 90,000 more companies than were registered with the dual systems in pre-LUCID times. Gunda Rachut expects a total of up to 260,000 companies to be registered by the end of the year, as she told a trade journalist. All of this prompts Dr Bettina Sunderdiek, Head of Communications and Press at the ZSVR, to say: „The message has reached the market.“
„Instability of the dual systems“?
The dual systems have been on the move since the launch of LUCID. There were nine different providers at the beginning of the year. There are now only eight. On 5 March, the Cologne-based company „Recycling Kontor“ announced that it was discontinuing its dual system „RKD Recycling Kontor Dual“ for economic reasons until the end of March. All RKD customers will have to look for a new dual system. Recycling Kontor has announced that it will strategically reorganise itself and, among other things, expand its range of Disposal of transport packaging and to offer digitalisation solutions and consulting services.
For many companies, the loss of RKD meant considerable additional work. They have to Registration and reporting procedures with a dual system.
[infotext icon]How did the LUCID launch go in practice?
How did the introduction of the packaging register work in practice? The member companies of the Rhineland-Nassau Farmers' and Vintners' Association have experienced a lot. Among other things, they had to find a new dual system at short notice. Find out more here.
[/infotext]Elsewhere, political planning is stalling. In Münster, Westphalia, the city council announced in mid-March that the project for the Waste management companies Münster (AWM), from 2020 a yellow Recycling bin instead of the yellow bags may be delayed. RKD was the negotiating partner on the side of the dual systems.
AWM operations manager Patrick Hasenkamp called the incident „another inglorious chapter in the history of packaging disposal in Germany“ and criticised the „instability of the dual systems“.
Financing fund for incentive models?
This appears to be the start of a development that Reinhard Schneider, head of the detergent, care and cleaning product manufacturer Werner & Mertz, in January in a highly acclaimed open letter had warned. With regard to incentive models for recycling-friendly packaging, „dumping models“ of individual dual systems were circulating, which may not be sufficiently financed. RKD Managing Director Dr Florian Dühr also lamented a „highly speculative price war“.
At the time, Reinhard Schneider proposed a different arrangement for the Incentive systems suggests: „One solution could be the creation of a joint cross-provider financing fund.“ With this suggestion, he seems to be knocking down open doors at the dual systems. Michael Wiener, CEO of the dual system „Der Grüne Punkt“, explained when asked about the planning status for incentive systems: „We are currently preparing an offer for our customers. From our point of view, however, there must be an overarching solution, for which we have already made a practicable proposal. This envisages a cross-industry recycling fund from which packaging that is suitable for recycling can receive funding based on objective criteria.“ The dual system „Reclay Systems GmbH“ was in favour of a standardised, comprehensive incentive system for recycling-friendly packaging. On the part of the Dual System of BellandVision GmbH, on the other hand, the Cartel Office sees a Fund solution critical. In addition, such a solution would be extremely difficult to implement operationally if you wanted to make it tamper-proof. The company itself is talking to customers about possible incentive models and, on request, also offers „Manufacturer-related“ licence prices for „good“ and „bad“ packaging.
Still unclear about the quantity reports
From the dual systems' point of view, how does the practical implementation of the packaging quantity reports work in principle? The responses to our questions were similar.
„The new regulations on registration and quantity reporting under the Packaging Act point in the right direction, but still need to be implemented in a practical way in some areas.“
Dr Fritz Flanderka, Managing Director of Reclay Holding GmbH
It is obvious that more companies have to fulfil their Obligation to report fulfil. Reclay Systems, for example, reports a „significant increase in Quantity reports with a focus on the small customer segment“. BellandVision points out that the increase in volume reports cannot be explained solely by former „free riders“. Since this year, all subsidiaries have also had to submit individual reports. Previously, collective reports from the parent companies were sufficient.
Grüner Punkt CEO Michael Wiener is still expecting a subsequent rush of distributors of Lightweight packaging. The latest planned volume reports from the ZSVR showed hardly any changes compared to the same period last year. BellandVision provides specific figures: „In the first quarter of 2019, there was a year-on-year increase of around five per cent in the dual licence volumes for lightweight packaging from the Yellow Bag/Yellow Bin, an increase of around 5.5 per cent for glass and around eleven per cent for PPK.“ Overall, the volume reports were still „below expectations“.
„There are many individual cases, some of which the obligated manufacturers are at a loss to deal with.“
Michael Wiener, CEO „Der Grüne Punkt“
Of course there were „certain Starting difficulties“, admits Reclay Systems. Nevertheless, the reporting processes of the packaging register are „by and large practical“.
The reporting system to the ZSVR has already become simpler and more convenient over the past three months, BellandVision praises. For distributors, in addition to registering with the ZSVR for the first time, this is now only a Duplication of their reports, which they had already completed for the dual systems.
