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On 31 August 2023, the updated version of the German minimum standard for assessing the recyclability of packaging was published in agreement with the German Environment Agency (UBA) in its 2023 edition. One major change that was included in the draft of the consultation procedure was not adopted in the final version: the plan was to restructure Appendix 1, which reflects the existence of a sorting and recycling infrastructure for different types of packaging and demonstrates the need for individual proof of high-quality mechanical recycling. Merging columns 3B and 3C in Appendix 1 would have meant that some types of packaging (e.g. PP films) would have required itemised proof of their recyclability. According to the Central Packaging Register Office (ZSVR), the aim was to simplify the application of the minimum standard and promote high-quality recycling. However, due to the large number of comments received, the new regulation was not included in the 2023 edition. Nevertheless, the issue of taking greater account of available recycling capacities remains on the agenda and is to be revised for the next edition.
Edition 2023
The changes mainly affect glass packaging and polyethylene (PE) films larger than DIN A4. For PE films larger than DIN A4, ‘nitrocellulose-based printing inks in intermediate layer printing’ has been recorded as an incompatibility for recycling. Due to the low heat resistance of nitrocellulose, the mechanical recycling process is disrupted. In addition to an unpleasant odour and discolouration of the recyclates, strong, respiratory-irritating outgassing could be observed. Furthermore, glass components with a transmission factor of less than 10%, for example due to colouring or varnishing, may not be counted towards the available recyclable material. Adjustments have also been made to fibre-based packaging in order to specify the provisions of the previous year and present them in a clearer way.
Basic information on the minimum standard
The aim of section 21 of the Packaging Act, ‘Ecological design of participation fees’, is to create awareness among manufacturers of the environmental impacts that arise throughout the entire life cycle and especially during disposal as a result of the manufacture and design of their packaging. According to § 21 VerpackG, the dual systems in Germany are obliged to create financial incentives either for the use of materials and material combinations that can be recycled to the highest possible percentage, taking into account the practice of sorting and recycling (§ 21, section 1, no. 1) or for the use of recycled materials and renewable raw materials (§ 21, section 1, no. 2).
On 1 September each year, the Central Packaging Registry (ZSVR) publishes the ‘Minimum standard for assessing the recyclability of packaging subject to system participation requirements in accordance with section 21 (3) of the Packaging Act; in agreement with the German Environment Agency’ as a basis for assessing the dual systems. On 1 June of each year, the dual systems must submit a report to the ZSVR explaining how they have implemented section 21 of the VerpackG. The minimum standard is updated and further developed annually based on technical progress and the dual systems’ reports.
In principle, the recyclable content of a packaging that is at least available for recycling is considered when assessing recyclability. The following three criteria must be observed:
- Existence of a sorting and recovery infrastructure for high-quality material recycling
- Sortability and separability of the packaging or packaging components
- Absence of recovery incompatibilities that could prevent successful recycling in practice
A study by the German Environment Agency (UBA) is used to determine the specific sorting and recycling capacities for the different types of packaging on an annual basis. The minimum standard is further developed on the basis of the results. The findings from the latest report ‘Practice of sorting and recycling packaging in accordance with § 21 VerpackG 2021/2022’ have already been taken into account.
We will be happy to advise you on how the new minimum standard could affect the recyclability of your packaging.
