A draft bill for the German Packaging Law Implementation Act (VerpackDG) suggested creating a prevention organisation – to be financed by domestic businesses at an estimated cost of approximately 89 million euros per year. This organisation would be responsible for implementing measures aimed at waste prevention and reducing packaging. However, a broad alliance of industry, trade and waste management associations had taken a clear stand against the establishment of such an organisation. In a letter to Parliamentary State Secretary Gitta Connemann (CDU) at the Federal Ministry for Economic Affairs and Energy, the associations distinctly called for the provisions to be removed from the Act.
The associations had also criticised the fact that a central prevention organisation, in combination with the associated extension of funding obligations, by far exceeds the guidelines of the EU Packaging and Packaging Waste Regulation (PPWR); Extended Producer Responsibility as well as deposit and return schemes in all Member States, are only required to set aside a minimum proportion of their budget for prevention and reduction measures. An additional body is neither explicitly provided for nor necessary for this purpose. This is now also stated in the current cabinet draft, as it provides that all producers, retailers and other organisations covered by Extended Producer Responsibility should independently fund reduction and prevention measures to minimise and avoid packaging waste.
At this stage, VERE had already expressed concerns and firmly rejected the proposed prevention organisation. The additional financial burden of such an instance would have meant companies needing to pay an additional five euros per tonne of packaging material. On top of this, the lack of a clearly defined and transparent usage for these funds made it difficult to discern any real added value. Having relevant systems and producers co-finance established waste-avoidance measures, based on volume, is entirely sufficient in this regard and continues to be supported by VERE.
In a separate article, we outline specific requirements of the Packaging Law Implementation Act (VerpackDG) as well as the associated expectations placed on companies.
If you would like to get individual training on the EU Packaging Regulation or an assessment of your role within your supply chain, VERE e.V. recommends the PPWR training courses from trade-e-bility. Please feel free to contact our colleagues at trade-e-bility directly on +49 40/750687-300 or send us an email.
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