As an SME association, VERE e.V. also monitors the positions and actions of the leading industry and waste management associations. As a VERE member, you can find a summary below of the major stakeholders' positions on packaging law in this sector:
Euwid reports that the Bundesverband der Deutschen Industrie (Federation of German Industries – BDI) criticises the draft of the German Packaging Law Implementation Act (Verpackungsrecht-Durchführungsgesetz) as going beyond EU requirements and placing an unnecessary burden on companies: In particular, producers are expected to fulfil additional obligations such as registration, authorisation, and financing agreements, which would entail significant effort without any discernible benefit for the circular economy. Furthermore, the association sees uncertainties regarding the new definition of “producer” and calls for practical transitional rules as well as a de minimis threshold for small quantities. Retailers and distributors could also be more heavily involved through expanded system participation obligations, though unclear definitions create additional risks. Fundamentally, the BDI criticizes the lack of market incentives such as eco-modulation, condemns growing bureaucracy, and instead calls for proportionate rules, greater planning certainty (e.g., through pooling for reusable quotas), and closer alignment with European guidelines. Further information is available in the BDI’s statement on the EU Packaging Regulation Implementation Act (VerpackDG-E)
The Bundesverband der Deutschen Entsorgungs-, Wasser- und Kreislaufwirtschaft e. V. (German Federal Association of Waste Management, Water, and Recycling Industries – BDE) takes a nuanced view of the draft: For producers and retailers, this approach especially aids the implementation of environmentally based system fees, which, despite criticism from the BDI, are meant to encourage recycling-friendly design and increased use of recycled materials through targeted incentives. At the same time, like the BDI, it calls for practical transitional rules regarding the new definition of “producers” to avoid funding gaps and rejects additional bureaucracy as well as unilateral national measures that go beyond EU requirements. Unlike the BDI, however, the BDE places greater emphasis on the stability of waste management and recycling structures: It warns against unrealistic quotas, overly frequent adjustments, and a weakening of material recycling, while the BDI places greater emphasis on the burdens and competitive disadvantages for obligated companies.
The BDI, BDE, and bvse (German Association for Secondary Raw Materials and Waste Management) largely share a common position on the EU Packaging Regulation (PPWR): They call for industrial and commercial packaging to be largely exempted from the regulation’s central requirements, as this packaging typically circulates within closed logistics and take-back systems and is already being used efficiently. For manufacturers and retailers, they specifically reject reuse quotas, extensive reporting obligations, labelling requirements, and detailed technical rules as impractical and bureaucratic. While the BDI justifies this position primarily by citing additional burdens and competitive risks for companies, the BDE and bvse place greater emphasis on the functionality of existing recycling and take-back structures. A difference emerges on the topic of eco-modulation: While the BDE generally supports this as a sensible regulatory instrument, the associations view its application to industrial packaging critically within the joint PPWR context. Overall, all three advocate for a clearer focus of regulation on consumer packaging and for greater practicality in industrial supply chains. Further information can be found in the joint association paper 260311_PPWR_and_EU-Environment_Omnibus_Debureaucratization_of_Industrial_and_Commercial_Packaging_final_1.pdf.
Become a VERE member now and stay on top of all latest developments by reading our very own “VERE Insider”.
