Draft of the minimum standard for assessing the recyclability of packaging 2024 is in the consultation process

On 1 September 2019, the minimum standard for assessing the recyclability of packaging was published for the first time by the Stiftung Zentrale Stelle Verpackungsregister (ZSVR). Since then, it has been an important tool for assessing the recyclability of packaging. The content of the German minimum standard is revised annually. Based on the work of a group of experts in consultation with the Federal Environment Agency, the ZSVR has prepared the draft for the 2024 edition. The consultation process started on 4 June 2024 and there was an opportunity to submit written comments until 12 July 2024.

What’s new in the 2024 edition?

Extract of the planned changes from the current draft

• New transition period: The minimum standard will be published as usual from 01 September 2024. This time, it will only apply for the first time from the following calendar year (in this case from 1 January 2025). The aim is to achieve better harmonisation with the system participation agreements.
• Definition of the object of assessment: “may” has been changed to “are”. Individual packaging components “must” be assessed separately in order to record their recyclability more precisely. Still formulated as an option in the current minimum standard.
• Itemisation: More specific requirements have been formulated for the documentation of itemised records that can be created by the dual systems. The requirements include standardised specifications for test results in order to ensure comparability and legal certainty.
• Materials not mentioned: Clearer regulations have been included for materials/types of packaging not explicitly mentioned (e.g. compostable plastics).
• Classification of liquid cartons: Adaptation to improved recycling capacities, as a result of which certain itemisations are now no longer mandatory.
• Specification of measurement requirements for testing identifiability: Packaging features that require testing to prove detectability have been added for plastic packaging and liquid cartons.
• Recycling incompatibilities: A clearer presentation of recycling incompatibilities and their exceptions has been provided. Due to recent investigations, there is now updated evidence for PA layers and PE-X components in the area of PE-flex, which will be taken into account in the draft for the consultation of the new minimum standard.
• Cancellation of the size criterion for PE-flex (Annex 3): The size criterion for PE-flex has been deleted, as modern sorting facilities can also successfully collect small-format PE-flex (< DIN A4) for recycling. This leads to new recycling incompatibilities and reference applications for small-format PE-flex.

It remains to be seen which of the changes mentioned will finally be implemented. All manufacturers of packaging subject to system participation are affected by the changes. You can find more background information on the minimum standard here. We would be happy to advise you on the impact the new minimum standard could have on the recyclability of your packaging.