German law forces packaging innovation on importers

Exporters to Germany are facing growing restrictions on how to package their goods - and users of plastic packaging may soon face disposal and recycling costs double those originally quoted as the new German packaging law bites. The answer, say German packaging experts, is not to use secondary packaging, and to ensure that transport packaging is reusable.

The packaging legislation and the infrastructure developing to deal with it has confused many exporters to Germany (ENDS Report 201, pp 24-25). A conference held by the German Chamber of Commerce in London in March attempted to clarify the system. Further advice will be available when an English translation of a German guide to the law is published in April by packaging consultants David Perchard Associates.1On 1 April, stage two of the legislation comes into force for additional "secondary" packaging, following laws on "transport" packaging implemented in December. Primary "sales" packaging will be covered from 1 January 1993.

UK firms will need to determine in which category their packaging falls in order to decide when to act, who to deal with, and the likely costs involved. The ideal cost-avoiding package is a reusable package, agreed the German speakers at the seminar. But secondary packaging "should be avoided altogether," according to an environmental adviser to the Kassel Chamber of Commerce.

  • Secondary packaging: This includes blister packs around boxes of screws, plastic wrappers around chocolate bars, cardboard boxes around toiletries and similar materials used as an additional layer around the sales packaging for advertising, theft prevention and other purposes. However, additional packaging can be treated as sales packaging if the consumer uses it to ease product transport, such as shrink-wrap around a six-pack of beer cans.

    The law requires retailers either to remove and recycle secondary packaging when consumers buy their products, or to provide collection bins at their outlets - the "take-back" obligation. German retailers, not wishing to stand the costs and inconvenience of removing and recycling this waste, are trying to rid their stores of additional packaging. One of the largest, Tengelmann, advises suppliers to avoid outer packaging and, if this is not possible, to use fibreboard. UK exporters will continue to face customer demands of this kind.

  • Sales packaging: For sales packaging, the legislation provides for an alternative collection system - the Duales System Deutschland (DSD). This only collects approved packaging, identified by a "green dot", such as plastics, metals and composites from households and paper and glass from banks. It now covers 10 million people and is set to be expanded to 78 million by 1993. Simultaneously, 140 sorting plants and collection facilities are being built at a cost of DM 7 billion. Running costs will then amount to DM 2 billion per year - about £60 for each family.

    To finance this, DSD charges member firms a fee averaging DM 0.02 per pack. For plastics, a further fee, equivalent to 25% of the DSD charge, is demanded by the plastic recycling company VGK. But DSD is to soon introduce a new charging scale making plastics "much more expensive" - maybe twice as much, according to Edelgard Bially of DSD. The revenues will subsidise collections and pay for experimental sorting and recycling projects.

    For the UK exporter who decides not to leave the arrangements to his German distributor, a contract with DSD is all that is required to meet the demands of retailers such as Tengelmann. If the package includes plastics, VGK should be involved, while aluminium users should inform the recycling company DAVR.

  • Transport packaging:
    The system in this area is more complex because there is no body co-ordinating collections and recycling. Firms may take back packaging themselves, or switch to reusable packaging. Alternatively, the distributor may employ a collection network such as Resy (ENDS Report 200, p 14) or Interseroh AG, an initiative of over 100 waste disposal firms. Tengelmann is encouraging reuse.

    Resy only takes waxand bituminous-free fibreboard with recyclable or easily removable labels. It may eventually collect films, wood, expanded polystyrene, tinplate and plastic packaging, but at present no formal system exists for these. This may change when a new company, RVT, is launched in the autumn for all materials.RVT hopes to emulate DSD's role in sales packaging, with Resy and Interseroh as partners. Charges of £17 per tonne for cardboard, £230 per tonne for plastic and £700 per tonne for polystyrene will be invested in collections and recycling.

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