Minimum Standards for Packaging Recycling: New Approach Next Summer
The new 2023 minimum standards on packaging recyclability have been published, and they come with less excitement than expected. While contentious decisions have been postponed until next year, this year's guidelines focus on light transmission of glass and the use of nitrocellulose in printing inks.
The minimum standards are published by mutual agreement between the Central Packaging Register Office (ZSVR) and the Federal Environment Agency (UBA) to enable the recyclability of sales and secondary packaging to be determined methodically on a uniform basis. It is not only the packaging industry that is eagerly awaiting the publication; the guidelines defined therein are also of sustainable relevance for trade and the branded goods industry. Last year, the team around ZSVR board member Gunda Rachut took a closer look at packaging made of paper, cardboard and carton. The verdict in September 2021 was: “A trend with a fibrous aftertaste: In the course of 'plastic bashing', more and more fibre-based packaging is being produced in which, among other things, pasta, coffee or sausages are sold. Although these suggest an ecological added value to consumers, in reality they are often more difficult to recycle than pure plastic packaging”. That was a statement that hit home. Not everything that looks sustainable is ecological.
This year, the big excitement failed to materialise, because the so-called “consultation procedure” between the stakeholders from trade, industry and dual systems (waste disposal companies) was controversial this summer. No common denominator could be found in the voting. Controversial decisions were therefore postponed until next year. The point of contention here was the planned restructuring in the so-called Annex 1, which depicts the existence of sorting and recycling infrastructure for different packaging or the requirement for individual proof of recycling. Many stakeholders saw this as an excessive burden on the system participants. In all likelihood, this would have resulted in a flood of individual certificates for the distributors and their packaging. An insane amount of additional bureaucracy. At the packaging register in Osnabrück, however, there is agreement: “The path of focusing more on recycling capacities is the right one and will be pursued further, but not with the minimum standard of 2023,” Rachut informs us. In any case, the topic is given high priority in the draft of the planned European Packaging Regulation. It is to be expected that packaging will always have to be reusable or recyclable in the future, even if concrete requirements and limit values of the expected European regulations have not yet been conclusively defined. According to the ZSVR from Osnabrück, it is an opportunity to prepare for this at an early stage and in a structured manner and to ensure the marketability of the packaging solution.
The most important innovations this year are: In the current minimum standard, a limit value for the light transmission (translucency) of glass was defined. This determines whether packaging made of glass is recyclable. If a glass packaging is not translucent, it is sorted out in the plants as a contaminant because it is not recyclable. This is the case with lacquered bottles, for example. In addition, the minimum standard now sees nitrocellulose in printing inks as an obstacle to recycling. Nitrocellulose-based printing inks in intermediate printing are therefore classified as non-recyclable. Due to a limited temperature resistance, they impair the mechanical recycling process and reduce the quality of recyclates. However, this only affects a relatively small, manageable market segment.
As with the gold standard, the minimum standard is probably not suitable for everyone in the recycling value chain. The ZSVR's founding body, the Industrievereinigung Kunststoffverpackungen (IK), of all people, has announced through its managing director Dr Isabell Schmidt: “The minimum standard is aimed exclusively at the dual systems. Contrary to what is sometimes perceived, it is not a binding 'design for recycling' guideline for industry.” In other words, the new classification has no influence on marketability. Financial disadvantages in the context of participation fees in the dual systems are also not to be expected at present. The latter could change, however, if the Federal Government decides on the announced reform of Section 21 of the Packaging Act. An incentive system is then to reward the distributors of high-quality recyclable packaging.