What Manufacturers Need To Consider In 2022

Anyone putting packaging into circulation bears responsibility for the product. In this interview, Gunda Rachut, Chair of Germany’s Central Packaging Register (ZSVR), explains what manufacturers need to consider and which regulations have been added in 2022.

Ms Rachut, what conclusions can be drawn after three years of amendments to the Packaging Act?

Gundula Rachut: After three years, the outcome is very positive. This law ushered in a turnaround in the assumption of product stewardship and at the same time created significant impetus in the recycling segment: more than four times as many companies as in 2018 are taking responsibility for their products. Recycling system participation volumes have increased significantly in all material categories. Ambitious recycling rates, the minimum standard for recyclingcompliant design, and the transparent packaging register LUCID are just some of the positive aspects associated with the impact of the Packaging Act.

How have packaging volume and the recyclability of packaging changed since then?
Figures from the German Environment Agency show an increase in packaging consumption for 2019. This trend was boosted even more due to
the much higher volume of ecommerce and foodtogo sales during the pandemic.

Two trends are emerging in packaging recyclability: The Central Packaging Register’s (ZSVR) minimum standard is having an impact, as increasingly
more plastic packaging can be recycled. On the other hand, “plastic bashing” and the discussion about a plastic tax are having an adverse effect, as mono packaging is increasingly being replaced by composite packaging, which is more difficult to recycle. However, a positive development is that the
recycling volumes from Germany’s dual system increased again in 2020 and were up 8.4 percent compared with the previous year.

What new rules will manufacturers face in 2022?

Rachut: This year, the amendment to the Packaging Act presents some significant changes for distributors of packaging. Effective 1 January 2022, certain single-use beverage containers are subject to a mandatory deposit scheme. On 1 July 2022, an extended registration requirement for all companies distributing packaging filled with goods will enter into force. Whereas until now, only manufacturers of packaging subject to mandatory dual system participation had to register in the LUCID packaging register, this obligation now applies to all types of packaging, i.e., including transport packaging, industrial packaging or reusable packaging.

Which sectors need to be particularly proactive this year?

Rachut: From July 2022, final distributors of service packaging subject to mandatory dual system participation will be obliged to register in the
LUCID packaging register if they have delegated their obligations in full to an upstream distributor. These are companies that buy their service packaging from a supplier already registered in the system and thus have already paid for the recycling of their packaging.

Obligations will also be imposed on the operators of electronic marketplaces from July 2022. They may only allow the marketing of packaging subject to system participation if sellers have met their registration obligations and are participating in a recycling system. The same applies to fulfilment service providers, who may only work for companies that have met their product responsibilities (registration, system participation).

Have there been some missteps on the part of manufacturers? Where
do you see a particular need for action by manufacturers?

Rachut: There are more and more manufacturers who are using the marketing effect of ecological packaging design. These are trends like refilling, pooling solutions in the to-go segment, and the use of recyclates in packaging. Consumers continue to have difficulties recognising ecologically sound
packaging. Although increasingly, brown paper is being used in packaging, it is not the distinguishing feature of recycling-compliant packaging. Often, the opposite is the case, as having a lot of composite materials makes recycling more difficult. Because the fibres are often insufficiently detached from the plastic layers only a small proportion is turned into new packaging.

Is the Packaging Register involved in the EU’s plans to introduce a new packaging directive? What changes could be in store for manufacturers at a European level when putting packaging on the market?

Rachut: The Commission’s Directorate-General for the Environment has announced a draft of a revised packaging directive for the middle of the year. If possible, packaging should be reused several times, should be made from a minimum amount of material, and should be recyclable. In this conjunction, the Directorate-General for the Environment has been following with great interest the ZSVR’s minimum standard for measuring the recycling-compliant design of packaging. As a supporting measure, there has been discussion of the idea for ecologically inferior packaging to cost more within the framework of product stewardship. Naturally, the recyclates produced should also be re-used, and this is something that is also being considered.