Published on 26. September 2022

Updated on 4. November 2022


Design for Recycling

Minimum Standard 2022 published

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The new minimum standard

The German Packaging Act (VerpackG) stipulates the annual publication of a minimum standard by the Central Packaging Register (Zentrale Stelle Verpackungsregister – ZSVR) in coordination with the Federal Ministry of the Environment. This minimum standard specifies which criteria determine the recyclability of packaging.

On September 1st, the current minimum standard 2022 was published.


Table of contents


Recyclability of packaging as a competitive advantage

The degree to which packaging performs well or poorly in the recycling process is an important factor for the success of high-quality recycling. Many different aspects play a role in this performance. Starting with the main material of the packaging, through proportions and details of other components, the type and coloring of the packaging, to the material of the label. Packaging that has already ensured good recyclability during the manufacturing process can be recycled more easily after disposal and enables the extraction of high-quality recyclates to be used in new products. Thereby, packaging waste is sensibly recycled and at the same time natural resources are conserved.

Rewarding the production of recyclable packaging with incentives can be a way to promote these positive effects. Companies that produce packaging have to pay fees for the quantities brought to market. Thereby, they participate in the German “dual system” and commission the programs (producer responsibility organizations – PROs) to organize the collection, sorting and recycling of the packaging. According to the German Packaging Act, the PROs are obliged to create incentives for the recycling-friendly design of packaging on the basis of the minimum standard. It is therefore worthwhile for companies to pay attention to recycling-friendly design when manufacturing packaging.


Current trend: More appearance than substance

Like its predecessors, the minimum standard 2022 is also based on minimum criteria that take into account the quality of material available for recycling. The minimum criteria stipulate that…

  1. … the necessary infrastructure for high-quality sorting and recycling must be in place for the assessed packaging.
  2. … the assessed packaging or the processed packaging components must be sortable and separable.
  3. … there are no substances in the packaging or packaging material that have recycling incompatibilities and would therefore negatively impair the recovery success.

These and further criteria are intended to ensure that packaging is evaluated with a sound methodology and on a uniform basis. This is meant to prevent that packaging only appears to be produced “sustainably”, while in reality it cannot be recycled at all or only to a limited extent. According to the analysis ZSVR published in the course of releasing the minimum standard 2022, a trend to seemingly sustainable packaging can be observed. The ZSVR reports, among other things, that more and more fiber-based packaging is currently being produced as a consequence of wide-spread “plastic bashing”. Thereby, manufacturing companies are responding to changes in the behavior of their consumers, who are placing ever greater emphasis on sustainable packaging.

In fact, however, this fiber-based packaging only suggests an ecological added value – in the recycling process, they perform worse than, for example, unmixed plastic packaging. The recycling performance of fiber-based packaging depends to a large extent on whether and how well the fibers dissolve during recycling and can thus be reprocessed.


Minimum standard 2022 responds to rise in fiber-based packaging

For this reason, a detection regulation for poorly recyclable fiber-based composite packaging is one of the various adjustments in the current version of the minimum standard. For such fiber-based composite packaging, proof of recyclability must now be provided in some cases. Incidentally, this requirement also applies to paper packaging that contains liquid or pasty.

The Minimum Standard 2022 also responds to other packaging trends that are not conducive to recycling from the point of view of the ZSVR. Overall, according to its report, the ZSVR sees significant progress in terms of “Design for Recycling” – but there is still potential for optimization in many ways, which the new minimum standard tries to raise in 2022.

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