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„No national solo efforts“

The food chain associations criticised the key points of the amendment to the Packaging Act. An interview with Karsten Hunger from the IPV.

Things are happening - at European and German level. While the planned Packaging and Packaging Waste Regulation is being finalised in Brussels, the Federal Ministry for the Environment recently presented key points for an amendment to the German Packaging Act. However, the food chain associations are clearly criticising this. In a joint statement, Karsten Hunger, Managing Director of the Industrial Association for Paper and Film Packaging (IPV), said that the planned amendment comes at an „inopportune time“. In an interview with packaging journal, he explained what is needed now and what challenges companies are currently facing.

Karsten Hunger, IPV
(Image: IPV)

Would you like to tell us what the companies in the sector are telling you? What are the challenges with regard to the amendment of the German Packaging Act?

In principle, the main problem lies in the general overload of new and sometimes poorly crafted regulatory requirements. This is one of the main sticking points. We represent small and medium-sized companies in Germany, at least in our association, but also in several other associations that have participated. And they are constantly having to deal with new regulations. Laws passed under time pressure subsequently require extensive guidelines and concretisation, as the formulations used are ambiguous. In the meantime, people have already come to terms with the fact that there will be new regulation in Europe and are expecting major changes. And suddenly there is, to put it bluntly, an unnecessary rush job from Germany.

An amendment to the Packaging Act is to be implemented just before the deadline. Many SMEs are rightly saying, what's the point? Are we now changing something in Germany that may have to be reversed in a year and a half? We are starting to go it alone again at a national level, when we are all trying to create a single European market wherever possible. There is no longer one German market and one French market and so on, many companies have shares in the export business. If different measures are taken in different countries, this will at some point overwhelm small and medium-sized enterprises in particular. That is why we are in favour of a standardised European approach.

What do you think about the European regulation that is now on its way and is also being hotly debated?

Of course, we also have our points of criticism in certain areas. The PPWR is much more comprehensive than the German amendment, so there are of course also points that we cannot agree with. Every passage and every formulation is the subject of fierce debate and discussion. But the point that we keep emphasising and that is important is to create uniform European rules and a level playing field for all market players - instead of individual processes with national taxes that are levied on top, labelling regulations that only apply in individual countries, completely different licensing fees - this whole patchwork in Europe is a hindrance.

You get the impression that there is a tension between reusable and recycled or recycled packaging. What is the current situation? Where do you see the difficulties and perhaps also the opportunities?

I think the main difficulty is that the whole topic is very complex. At first glance, you think, yes, reusable packaging, it used to exist, it used to be very common, it's fine again today, we just need to work on our habits a bit. But this ‚just work on our habits‘ is not so easy. Today, life and work concepts have changed significantly. And the business models of restaurants, takeaway chains and so on have also changed. What's more, we now have other problems to contend with, such as the need to save CO2 and pay attention to water consumption. And this mixed situation means that we have to take a closer look at what is ecological and sensible in one place and perhaps not in another. It used to be the case that a shop restaurant had a relatively large kitchen with lots of space and plenty of staff to wash and dry dishes if necessary. The crockery had time to dry properly. If you look at the situation in large cities today, especially in highly frequented locations, everything looks very different. An incredible number of customers come in a very short space of time and want to eat something very quickly. How can these quantities of crockery be hygienically washed and dried? Where will the additional space suddenly come from? How can the additional staff be found? For these reasons, we are in favour of taking a closer look. Where does reusable make sense, and where is good recycling the better option? You can't generalise. No blanket 30 or 50 per cent reusable quotas will help, but firstly the circumstances must be right and secondly the incentive for customers must be created. Because it has to be said that there is not yet a great deal of customer acceptance for reusable packaging. So we also have to look at why this is the case. And it's not necessarily because there aren't enough reusable options, but also because it simply doesn't suit some phases of life or some working lives. This is our central point of criticism: instead of blanket quotas, we need to examine ecologically what is actually possible and sensible with reusable packaging, and where it is simply enough to stay with disposable packaging but improve waste separation and recycling. Incidentally, this has already been recognised in the parliamentary debate on the PPWR and in the EU Commission's Environment Committee, in which many articles on reusable packaging have already been deleted or adapted compared to the first draft.

How could this look or be regulated by law? Do there have to be a lot of detailed regulations?

I believe it will ultimately be a mix of different regulations. In the end, there will have to be some kind of incentive, a regulation that makes it worthwhile for distributors to actually use reusable products. For some people and customers, reusable packaging may be worthwhile and the right option. But there will be quite a few cases where it doesn't work for structural reasons or for reasons of hygiene.

What are companies already doing at the moment? What do you see in the industry that is already working well and could perhaps be expanded?

Recycling is of course one of the main topics. The attempt, particularly in the catering industry, but also in other areas, to achieve significantly better separate collection of waste and then to create defined recycling streams from this is definitely there. Consumers are also becoming more and more environmentally aware. And they have a certain interest in ensuring that disposable packaging and waste are handled well. And of course, consumers also have a certain power to say that something is not wanted. They then opt for reusable packaging or put pressure on the distributor. You also always have to say that we have a functioning recycling system in Germany. This may be a little more difficult in other countries. In these countries, we have to work harder on the overall system. But this image of disposable packaging from Germany that ends up in the sea somewhere is not true. It's an impressive misconception that people like to try and create from time to time. But that's definitely not the case.

You have criticised the planned amendment. What would you like to see in the future? What needs to be done now?

In principle, I would like to see a stop to the points in the amendment that affect the PPWR. That work on a German amendment is stopped at this point and all efforts are channelled into the PPWR so that we can actually get it over the line in 2024. The topics that are not discussed in the PPWR can be discussed. A limited amendment could be drawn up and implemented as quickly as possible. Otherwise, I would really like to see such ideas discussed in advance with the industry or on a larger scale, particularly with the involvement of the scientific community. Unfortunately, the neutral, analytical voice of science in particular is currently being neglected. Of course, we don't want to turn this into a pure lobbying event, but it would be nice to have a lively dialogue, including with NGOs. I would simply like to see good cooperation. We've had that in the past. And I also hope that the haze will clear a little in this case and that we might come to a solution where we in Germany say: okay, let's stop the controversial national projects first and deal with the European rules first.

http://www.ipv-verpackung.de

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