The new packaging registry started operations on 1 January 2019, when registration became mandatory for producers of packaging which typically accumulates as waste with end consumers. In the meantime, around 170,000 producers have registered. Despite intensive information activities, registration numbers and recycling rates are insufficient. Some producers are still not paying (enough) for collection and disposal of their packaging materials. The Central Office Packaging Registry has established effective mechanisms to verify which producers and systems are not fulfilling their obligations to the extent required. “The groundwork has been laid for the federal states to prosecute these offences. The federal states must take action and prosecute the offences with the manpower necessary for the task,” said Maria Krautzberger.
In terms of environmental protection, other important issues must also be clarified – first and foremost, packaging prevention. Packaging use in Germany is at a historic high and continues to increase. Producers and first distributors (online merchants) in particular can bring about a trend reversal. Packaging should be kept to the necessary minimum, and reusable packaging systems must become the standard. In the beverages sector in particular, the reusables share has been declining for years (only 42.2% in 2017). Examples of further potential to prevent packaging can be tapped from reusable packaging used in e-commerce shipping and reusable "to go" packaging for food and drinks.
In cases where reusable packaging is not an option, the packaging should have material-saving and recycling-friendly design and contain recycled materials whenever possible. In principle, many non-food packaging materials could be manufactured from the recyclates disposed in the yellow garbage bags and bins. Recyclates have been used in cleaning products and paints packaging. The EU Single-Use Plastics Directive sets a target to incorporate 25% of recycled plastic in PET single-use bottles as from 2025 and 30% in all plastic bottles as from 2030.
The Packaging Act stipulates that the companies in the Dual System should create incentives for producers to make packaging more recyclable. To support this the Central Office Packaging Registry and UBA have published a minimum standard for assessing recyclability. The standard indicates when the recyclability of a certain packaging type is good. Producers and trade are already using the minimum standard as a point of reference. UBA will be evaluating the extent to which the incentives created by the dual systems result in improved recyclability of packaging. Should their effectiveness not be sufficient, UBA will develop proposals for a readjustment.
UBA is already advising producers to stop using certain types of packaging which make recycling difficult. This includes "full-sleeve“ labels which cover the entire packaging or soot-coated and coloured plastic wrap, both of which are not properly recognised at sorting facilities and therefore improperly recycled. Consumers can also make a conscious decision to avoid such packaging and opt for other products.