Germany’s NF metals industry criticises “incomprehensible” amendment to Packaging Law
They both welcomed the announcement by the German Federal Ministry for the Environment (BMUV) that the draft law presented will allow various ecologically optimised packaging systems to coexist.
However, both AD and WVMetalle criticised the ministry's failure to take into account the expected European Union (EU) regulations.
Roland Leder, president of WVMetalle and vice president of AD, said: "The amendment to the Packaging Law is a German solo effort that is incomprehensible to our industry. In view of the planned new EU regulation, the German government's action is not efficient."
The draft's main new provision is the introduction of a reusable offer obligation for all final distributors of packaging. BMUV calculated that this will affect at least 16,000 sales outlets in Germany.
In Europe, only final distributors with a sales area of more than 400m² are to be affected by similar obligations, according to the current state of discussion.
This would mean that many very small businesses would be affected in Germany, but not in other EU countries, said the associations.
Leder observed: "A blanket promotion of reusable packaging by means of an obligation to offer reusable packaging is not expedient and is not based on scientific principles. This could displace deposit packaging such as beverage cans, which play an important role alongside reusable systems in the competition between ecologically optimised packaging systems. Cans are almost entirely returned to stores by citizens so they can be put back into circulation."
According to estimates by retailers, the new mandatory reusable offer would massively increase the expense in logistics, because reusable systems require significantly more truck trips in the take-back process.
Furthermore, additional expenses would have to be made for a reusable offer and its costly sorting and return - with massive consequences for prices on the beverage market.
"In order to increase the consumer's freedom of choice at the counter, the freedom of choice of businesses, often micro-enterprises such as kiosks, is severely restricted. Indeed, to ensure that consumers make use of the reusable offer, the German draft law contains far-reaching interventions in pricing and the sales process. We consider competitiveness achieved in this way to be extremely questionable," continued Leder.
Further interventions concern packaging that accumulates, for example, in larger restaurants with self-service. Here, there is set to be a ban on beverage cans or aluminium menu trays that are 100% recyclable, and almost completely collected via dual systems or deposit systems.
The mandatory deposit was introduced in 2003 by Federal Environment Minister Jürgen Trittin (Bündnis 90/Die Grünen) and was accepted by the population with great success, according to the associations.
It has led to return rates of 99% for beverage cans. Packaging made of aluminium, such as beverage cans or menu trays, already contains high proportions of recycled material in some cases and is usually reused for new packaging or other products after recycling without any loss of quality, they added.