Film manufacturers sound the alarm

The Central Packaging Register Foundation publishes an annual “Minimum Standard for Measuring the Design of Packaging for Recycling”. This is criticized by companies such as Buergofol and Südpack, which produce multilayer film packaging.

Medium-sized companies that produce multilayer film packaging with functional polyamide layers are calling for a different designation for flexible films with a polyamide layer by the German Federal Environment Agency, the Central Packaging Register Foundation and the German Federal Government. In a letter, they criticize that the so-called “Minimum Standard for the Assessment of the Recyclability of Packaging Subject to System Participation” marks flexible films with a polyamide layer as being incompatible with recycling. Dr. Franz Schleicher, owner of Buergofol GmbH and co-signatory of the letter initiated by Südpack, criticizes that this creates the impression that these films are not environmentally friendly. “A one-sided promotion of the recyclability without consideration of the overall ecological effects interferes deeply with an existing market without any meaningful ecological steering effect. In this way, the good and correct objectives of the Packaging Act are reversed by setting false incentives for the industry. Such misleading demands are damaging to business, endanger jobs and destroy innovative SMEs”, the letter says. “At the moment, everything is running against films with polyamide,” says Schleicher.

Overall ecological advantages

The minimum standard should take into account the overall ecological benefits of the packaging and not just its recyclability. The proportion of polyamide in food packaging is only 1.7 percent, but it protects the majority of foodstuffs such as cheese or sausage. With a weight share of up to 5 percent, polyamide can be mechanically recycled in the polyolefin stream. However, due to the small proportion of polyamide in the waste stream, this multi-layer packaging is not sorted out separately by the dual systems, but ends up in the sorting residue and is recycled for energy.

Background: In accordance with statutory regulations, the Central Packaging Register Foundation must, in agreement with the German Federal Environment Agency, publish a “minimum standard for measuring the recyclable design of packaging” as of September 1 each year.

The addressees are the systems which have to calculate the system participation fees on the basis of this minimum standard. These in turn are obliged to place packaging that is suitable for recycling in a better financial position. “According to the Packaging Act, the assessment of the recyclable design in our minimum standard must be based on the current practice of sorting and recycling. So if packaging is not currently sorted or recycled accordingly, then according to the standard it must not be assigned a corresponding proportion of recyclable materials. The systems can use further criteria to measure the recyclable design, as this is a minimum standard. However, this is outside our remit. Furthermore, we have no tasks in the area of evaluation or approval of specific packaging items,” explains the Foundation in response to an enquiry.

Matthias Fabian, head of the “Implementation of the Packaging Act” department at the German Federal Environment Agency, explains that the minimum standard is intended solely to determine the recyclability of packaging typically generated as waste by private end consumers, and which is usually collected via the collection by Dual Systems and then sorted and recycled by the systems. Here recyclability is a gradual characteristic which can only be determined for the specific packaging as a whole and which must be determined under the actual market conditions for packaging waste. In this respect, it is essential that suitable sorting and recycling paths exist for packaging in practice, explains Fabian. He emphasizes: ” In accordance with the legal requirements other aspects of ecological packaging design are not covered by the minimum standard”.


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