New version of the minimum standard for assessing the recyclability of packaging (2024)

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On 29 August 2024, the Central Agency Packaging Register (ZSVR) published the new minimum standard for assessing the recyclability of packaging in Germany.

Background: The minimum standard for assessing the recyclability of packaging was published by the ZSVR Foundation for the first time on 1 September 2019. Since then, it has been an important tool for assessing the recyclability design of packaging. The content of the German minimum standard is revised annually. The consultation process for the draft of the new version took place in June/July. RecycleMe provided information about the planned changes.

In principle, all manufacturing companies that place packaging subject to system participation on the market are affected by the changes to the minimum standard.

All changes from the consultation process have been adopted

Essentially, almost all of the changes that were discussed in the consultation process have been adopted.

Here is an overview of the most important changes:

New validity

• The new version of the minimum standard for assessing recyclability is only valid for the first time from the following calendar year and not, as usual, from 1 September. In this case, the minimum standard 2024 is valid from 1 January 2025.
• Background: Alignment with the usual period of the system participation agreements

Changed assessment of liquid cartons (FKN)

• When assessing the recyclability of liquid cartons, the cardboard content (fibre) of the composite carton was previously primarily taken into account. For the other components of the packaging – plastic and possibly aluminium – individual proof of high-quality recycling was required. With the new version, this individual verification is no longer mandatory, but is still recommended.
• Background: The recycling capacities for residual materials from the recovery of FRP (such as plastics and aluminium) have increased significantly. In the meantime, significantly more plastic and aluminium components of the FRP are being recycled into high-quality materials. Among other things, through systems such as PAluRec.

Flexible PE films – size criterion no longer applies

• In the 2023 minimum standard, PE films are differentiated by size: smaller or larger than DIN A4. This distinction will be abolished with the new version. The recycling incompatibilities listed now apply to all PE films – regardless of size. This also means that the recycling incompatibility ‘Nitrocellulose (NC) based printing inks in interlayer printing’ applies to all PE films (previously only for PE films > DIN A4). Anyone using NC-based printing inks in interlayer printing for their PE film should have the recyclability of their packaging checked and find out about alternatives.
• Background (size criterion): Sorting plants for lightweight packaging (including films) are increasingly able to sort and recycle small-format PE film packaging.
• Background (NC-based printing inks): NC-based printing inks in interlayer printing can have a negative impact on the quality of the recyclate (colour changes, unpleasant odour and respiratory irritant outgassing).

Outlook: Approximation of the minimum standard to the EU packaging regulation PPWR

For the upcoming minimum standard in 2025, it is planned to bring it closer to the regulations on recyclability of the EU Packaging Regulation (provided this has entered into force by then). This should help to ensure a smooth transition to the future EU-wide binding regulation for the economy.

RecycleMe advises you on all matters relating to recyclability

Would you like to know whether your packaging is specifically affected by the changes or whether the recyclability of your packaging has changed? We will be happy to support you in assessing your packaging. Or are you wondering which new requirements will apply to you at what point in time with regard to the new Packaging Ordinance (PPWR)? We will also be happy to advise you on this. We will be happy to advise you on what impact the new minimum standard could have on the recyclability of your packaging.