In August, the Central Agency Packaging Register (ZSVR) published the 2025 edition of the minimum standard for recyclable packaging in agreement with the Federal Environment Agency (UBA). While the ZSVR emphasises that the ‘current 2025 edition has been further developed at the request of practitioners and is already based on the system of the European Packaging Regulation (PPWR)’, many market participants still see a considerable need for clarification. Critics complain that political targets are increasingly at odds with technical realities – including Till Isensee, founder and owner of packaging and sustainability consultancy TILISCO GmbH.
‘The term “minimum standard” suggests that this is a technically standardised process – i.e. clear, uniform assessment methods. But that is not the case. The same packaging can achieve completely different results from different certifiers: from very recyclable to non-recyclable,’ says Isensee. He is referring to a core problem that causes considerable uncertainty in practice: the lack of comparability between assessment methods and the certificates derived from them.
In response to an enquiry from FACHPACK360°, the ZSVR explained that the expert group had been expanded again for the 2025 edition, ‘to include medium-sized companies, additional system operators and representatives of the Recyclate Forum, among others.’ . In addition, the status of the discussion in the CEN (European Committee for Standardisation) regarding the assessment of recyclability has been taken into account. "This ensured that the various perspectives were comprehensively incorporated into the revision. The technical basis for the definition of incompatibilities and recycling limits is the current UBA study ‘Practice of Sorting and Recycling’ of packaging. It describes which packaging can actually be sorted and recycled," emphasises the ZSVR. The study is updated regularly so that technical developments and the expansion of sorting and recycling capacities are continuously taken into account.
Till Isensee, on the other hand, fundamentally questions the legal basis of the minimum standard. "The minimum standard is based on Section 21 of the Packaging Act, which provides for a bonus-malus system for recyclable packaging. However, as this section has never been implemented, there is no legal basis – the minimum standard is only widely applied because retailers require it as a basis for assessing recyclability for listing and because there is currently no better technical basis. ‘I am a big fan of the minimum standard itself,’ says Isensee, ‘but the details need to be reworked!’
In other words, the standard is on shaky legal ground. The planned incentive system, which was actually intended to create financial advantages for particularly recycling-friendly packaging, does not yet exist. However, for the reasons mentioned above, there is no way around it.
The assessment of composite packaging remains particularly controversial. The official statement says that these types of packaging ‘continue to cause concern’ and are difficult to recycle. The ZSVR cites incorrect pre-sorting and inadequate waste separation by consumers as the main causes.
Isensee strongly disagrees: ‘It is not true that fibre-based composite packaging generally causes problems in recycling.’ He bases this on research findings and refers to a master's thesis (“Difference between political and technical recyclability”) that he supervised together with the Technical University of Berlin. According to Isensee, the result was clear: ‘For all packaging classified as “incompatible” or “non-recyclable” in the minimum standard, we were able to demonstrate technical solutions that make recycling possible.’
He is supported by INGEDE, the interest group representing paper recyclers and de-inkers in Germany. A study commissioned by INGEDE showed ‘that over half of this composite packaging ends up in the blue bin – and is then actually recycled.’
According to the ZSVR, the assessment is not carried out on a flat-rate basis, but on the basis of objective, comprehensible criteria. The results of the UBA study ‘Practice of Sorting and Recycling’ are also decisive for the classification in the assessment. Other studies are taken into account by the ZSVR, but are not directly included in the assessment, as their methodological approaches and data bases cannot be verified in detail.
Another point of criticism concerns the so-called 95-5 rule, which is often used in practice as a benchmark for recyclability.
For years, manufacturers have been trying to reduce the proportion of non-paper-based components to below five per cent. However, according to Isensee, this limit has nothing to do with recyclability, but exclusively with licensing under the Packaging Act: below five per cent, paper prices (approx. €120–150/t) apply, while above five per cent, the price is €600–800/t. In practice, it is rather thinner films that cause technical problems in paper mills. Thicker films, on the other hand, are easier to separate. ‘The industry is therefore not optimising recyclability, but primarily licensing costs,’ says Isensee. His criticism is that this has established a system that creates economic incentives but does little to promote ecological improvements.
A new passage in the minimum standard is providing additional food for discussion: under the heading ‘Incompatibilities’, specifications have been included that would have far-reaching consequences in practice. ‘Every coating – whether printed or applied – is now considered an incompatibility,’ explains Isensee. ‘This is currently causing considerable unrest in the industry because this definition was made without consultation with the parties concerned. It is factually incorrect and would ultimately mean that we would no longer be allowed to manufacture or market many of our products.’
The new regulation primarily affects paper processors and manufacturers of fibre-based composites who work with thin barrier layers. From an industry perspective, there is a threat of a conflict between ecological intentions and technical reality.
Despite all the criticism, the minimum standard remains relevant for many companies – albeit for practical rather than legal reasons. There is no legal obligation to comply with it. However, retailers demand proof of recyclability – and base their requirements on the minimum standard.
Anyone who wants to supply large retail chains therefore has little choice but to have their packaging assessed according to these criteria. As a result, the originally voluntary guideline has long since developed into a de facto industry standard – even without being enshrined in law.
Author: Alexander Stark, Editor FACHPACK360°
