The Evolution of Germany's Packaging Waste Laws
Wed Feb 21 2024

In November of last year we covered extended producer responsibility (EPR) bills in the USA that have emerged the past few years, but did you know that Germany has had an extended producer responsibility system for packaging since the early 1990s?

Germany was not only one of the first countries to implement an extended producer responsibility (EPR) system, they also experimented with 2 different approaches—The German Packaging Ordinance (1991–2019) and The German Packaging Act (2019—Present).

The German Packaging Ordinance (1991)

On July 12, 1991, the German government became one of the first nations in the world to pass an EPR bill to manage packaging waste with the Packaging Ordinance (VerpackG). The passing of VerpackG (Verpackunsgverordnung) was fueled by the fact that waste, particularly packaging waste (1/2 of landfill volume and 1/3 of waste), was pushing the capacity of landfills so nationwide change was needed to steer packaging waste away from them. 

The 1991 Packaging Ordinance came into effect in 1993 and contained provisions including:

  • Requirements for distribution packaging to be collected by producers and distributors in effort to be reused or recycled 

  • Identified distributors were required to remove “grouped packaging” when product was stocked on store shelves 

  • Distributors had to ensure that sales packaging was collected either with an EPR system or by way of a fee paid to a PRO that will ensure disposal of the packaging system 

  • Targets for collection, sorting, and recycling by substrate for 1993–1995

The collection rate targets (1993–1995) for different packaging materials included:

  • Glass60% 

  • Tinplate40% 

  • Aluminum30% 

  • Paper, cartons, and cardboard30% 

  • Plastics30% 

  • Composite materials20%

The sorted/sent for recycling targets (1993–1995) for different packaging materials included: 

  • Glass70% 

  • Tinplate65% 

  • Aluminum60% 

  • Paper, cartons, and cardboard60% 

  • Plastics30% 

  • Composite materials30% 

The recycling rate targets (1993–1995) for different packaging materials included: 

  • Glass 42% 

  • Tinplate26% 

  • Aluminum18% 

  • Paper, cartons, and cardboard 18% 

  • Plastics9% 

  • Composite materials6% 

In preparation for the Ordinance’s provisions, industry leaders created the Duales System Duetschland GmbH (DSD) in 1990—essentially acting as a single producer responsibility organization (PRO) which all producers or importers of packaging products had to join and contribute to financially (based on volume). Members could be identified by the use of “The Green Dot” trademark on their packaging.

The German Packaging Ordinance of 1991 is regarded as a foundational system upon which many EPR systems across the world are based today, but it was not flawless. 

For example, the DSD drafted service contracts based on volumes expected—expecting collection volumes of 11.4 kg to 13 kg per person in 1995 and, in reality, being faced with quantities of 20kg per person in many regions by 1993—which led to an array of problems for the DSD.

Additionally, the DSD experienced difficulties in verifying if collection, sorting, and recycling targets were being met, as determining such at the time required extensive analysis and often produced imprecise data.

Over time, and before being replaced by the German Packaging Act in 2019, the German Packaging Ordinance saw 7 amendments, listed below: 

  1. 1998 Amendment: A new approach to recovery quotas in which quotas had to be met through their own “take-back schemes” (a form of individual producer responsibility) and a change on how collection, sorting, and recycling rates were calculated (using “total amount of licensed packaging produced”).

  2. 2002 Amendment: The introduction of a mandatory deposit-refund scheme (DRS) for single-use beverage containers. 

  3. 2005 Amendment: The establishment of a clearing organization to assist with deposit-refund schemes (DRS).

  4. 2006 Amendment: The establishment of “new terms and targets” for collection, sorting, and recycling. 

  5. 2008 Amendment: The establishment of measures to ensure producer and filler participation in the system and to exempt firms who had their own established “take-back” schemes. The 2008 amendment also established the requirement of “Declarations of Completeness” filings (to document the amount of sales packaging put onto the German market by a particular manufacturer/retailer in a year, only to be submitted if identified volumes were exceeded). 

  6. 2013 Amendment: An amendment that served to clarify an array of technical terms and to provide guidance to members. 

  7. 2015 Amendment: The ability for participating firms to create their own take-back systems was removed, and new criteria for exemption from the EPR system was introduced.

Aside from the amendments above, in 2003, the system made a change that inspired the design of EPR systems in the US and worldwide in the present. The change was the ability for numerous producer responsibility organizations (PROs) to be created, shifting from a one-PRO model (the Duales System Deutschland GmbH running everything) to a model in which numerous PROs compete with one another in order to achieve the provisions set by the act. The move expanded competition between PROs and worked to reduce recycling and collection costs. It also ended the monopoly enjoyed by the single PRO (Duales System Deutschland GmbH) from 1991 to 2003. 

Despite the benefits of the 2003 change, the move also led to more complexity and numerous firms trying to exploit the system by not licensing all their packaging with a PRO. Without one sole PRO to register with and pay fees to, Germany’s EPR model became murky, but it also experienced a massive reduction in overall costs. 

However, despite the 7 amendments from 1991 to 2015, in 2017, the German Parliament saw a need to upgrade its nationwide EPR and packaging waste regulation—leading to the replacement of the German Packaging Ordinance (1991) with the German Packaging Act on January 1, 2019

From VerpackV to VerpackG—The German Packaging Act (2019)

Coming into force on the 1st of January 2019, the German Packaging Act works to replace the Packaging Ordinance of 1991.

The German Packaging act added a number of changes to Germany’s EPR and packaging waste management program, including the following: 

As mentioned above, the German Packaging Act of 2019 included higher recycling rates by packaging material, with both 2019 and 2022 rates, including the following: (those in green were met according to PREVENT Waste Alliance's EPR ToolBox)

  • Glass — 2019: 80% → 2022: 90%

  • Paper, paperboard, and cardboard — 2019: 85% → 2022: 90% 

  • Ferrous metals2019: 80% → 2022: 90%

  • Aluminum 2019: 80% → 2022: 90%

  • Beverage carton packaging2019: 75% → 2022: 80%

  • Other composite packaging2019: 55% → 2022: 70%

  • Plastics2019: 90% → 2022: 90%

  • Plastics (mechanical recycling)2019: 58.5% → 2022: 63%

In 2021, Germany's Federal Cabinet approved a new version of the Packaging Act that worked to integrate provisions from the EU’s Single-Use Plastics Directive, which was approved June 5 of 2019. The German Packaging Act amendment went into effect on July 3, 2021—the major changes include:

  • New requirements for producers who are exempt from participation (transport and reusable packaging) including establishing self-monitoring measures and ensuring distributors are educating consumers about return systems.

  • New requirements for deposit-refund schemes including “mandatory deposit for all one-way beverage bottles and drink cans” (exemptions for dairy products) by January 1, 2024.

  • New requirements to offer and educate consumers about reusable and take-back alternatives. 

  • Requiring registration of all packaging producers (including transport and reusable) with the Central Agency by July 2022. 

  • New requirements for minimum recycled content in PET bottles, with those less than 25% being banned for sale by January 1, 2025, and those with less than 30% being banned by January 1, 2030.

The Efficacy of the German Packaging Act 

As highlighted above, Germany’s passing of the German Packaging Ordinance (VerpackV) in 1991 marked the establishment of one the of the world’s first EPR and packaging waste management systems. You might be wondering, with Germany’s early focus on packaging waste management and EPR, are they world leaders in recycling? 

The ways in which studies calculate recycling rates for nations differ, but Germany is consistently found at the top of lists in the company of South Korea, Austria, and Slovenia. A 2021 study from World Population Review claims Germany has the highest recycling rate in the world—recycling ~56% of waste the country produces

When looking at how Germany compares to European Union nations in terms of the recycling rate of municipal waste (2021), Germany tops the list with 71.1%. Germany is significantly higher than the EU average in this category which was 49.6% in 2021. Only 7 other countries had a rate higher than the EU average, including Austria (62.3%), Slovenia (60%), The Netherlands (57.8%), Luxembourg (55.3%), Switzerland (53.3%), Belgium (53.3%), and Italy (51.4%).

Germany is also seen as a world leader in deposit-refund schemes (DRS) for beverage packaging. A TOMRA article from August 2023 highlights that Germany not only has the world’s largest deposit-return scheme, but also has a return rate of 98% on single-use drink containers. As highlighted above, Germany first introduced a mandatory DRS for beverage containers in a 2002 amendment, meaning they have had 20+ years to perfect the system.

It is evident that Germany’s early action and work on EPR and packaging waste management positioned them to be world leaders in the collection, sorting, recycling, and reuse of numerous packaging materials. 

Both the German Packaging Ordinance and the German Packaging Act serve as blueprints for EPR and packaging waste management systems that followed and are still in development.

Any packaging producer who plans to sell into the German market must comply with the German Packaging Act’s provisions or face major penalties. Even companies that are outside of Germany but sell into the country fall under the Act’s scope.

Here at the Packaging School, we offer an array of online courses and certificate programs to help packaging professionals and organizations prepare for monumental changes in the industry and regulatory environment.

Check out these online micro-learning courses to ready your company for emerging packaging regulations:

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