In agreement with the German Environment Agency, the country’s central packaging register office Stiftung Zentrale Stelle Verpackungsregister (ZSVR, Osnabrück; www.verpackungsregister.org) has published a new “Minimum Standard for the Assessment of the Recyclability of Packaging” as part of Germany’s Packaging Act.

Compared to the previous rule, the minimum standard unveiled on 31 August 2022 contains a number of changes, such as for composite packaging made of paper and plastic: due to “plastic bashing”, an increasing amount of paper-based packaging is being produced in which items such as pasta, coffee or sausages are sold. Although these suggest an ecological added value to consumers, they are often more difficult to recycle than single-material plastic packaging, the agency criticised.

It said in each individual case, the recyclability of fibre-based paper packaging currently depends on whether the fibres can be detached during the recycling process and thus be reprocessed into new fibres. This concern is reflected in the new minimum standard: for fibre-based composite packaging, proof of recyclability must now always be provided. There is an exemption for composite carton packaging for liquids, such as those produced by Tetra Pak (Lausanne, Switzerland; www.tetrapak.com) or SIG Combibloc (Neuhausen, Switzerland; www.sig.biz).

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Another change concerns PA layers in the “film and LDPE” fraction, which are usually considered “recycling-incompatible”. In future, PA 6 or co-PA 6/6.6 in coextruded polyethylene/polyamide film structures without an EVOH layer will be considered an exception.

German chemical producer BASF (Ludwigshafen; www.basf.com) welcomed this change, noting that the use of coextruded PE/PA film structures in multilayer films allows the production of very thin films, a downgauging that reduces the use of plastics and waste.

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Another refinement of the minimum standard also applies to glass waste. For example, metal nets and woven baskets slow down recycling and are assessed accordingly.

In the future, however, there will also be new regulations for product residues such as bitumen or nail varnish that remain in packaging. The influences of product residues must be considered when assessing recyclability, the ZSVR said.

As further examples of “counterproductive” developments in the packaging industry that are detrimental to recyclability, the foundation cites the increasing number of thermoformed multilayer PET trays – for which there is as yet no suitable recycling infrastructure – and for paper cups with coating on both sides. The central agency is also concerned about the increasing share of packaging made of wood, bamboo, and textiles, noting that since these cannot be sorted out, they are usually incinerated. Here, too, the minimum standard is likely to be readjusted in the coming years.

The fourth revision of the minimum standard retains the structure with three standard criteria: by determining the existence of a recycling infrastructure, the sortability and separability of packaging, and taking recycling incompatibilities into account, it can be determined whether packaging can be recycled well.

Based on the minimum standard, Germany’s dual waste management systems are obliged to create financial incentives for recycling-friendly packaging designs. Companies could therefore benefit from creating environmentally friendly packaging.

With the amendment of the Packaging Act, an expanded registration obligation went into effect for all types of packaging on 1 July. Packaged goods may only be distributed in Germany if the manufacturer is registered in the Lucid packaging register of the ZSVR.