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The riddle of the missing packaging

How is that possible? Volumes of waste collected by the ‘dual systems’ have remained at a constant level and yet licensing revenue is falling.

Dwindling volumes in the dual systems have now become a political issue


For years, reported quantities of licensed packaging material have been falling, whereas the actual amounts collected by waste management companies have remained more or less the same. Quantities which have to be collected and recycled without anyone paying for them. The FDP (Free Democratic Party) in North Rhine-Westphalia recently put a motion to the state’s red-green coalition government, asking for a response on how the Packaging Ordinance was being upheld. FDP member of the state parliament, Kai Abruszat, was referring to reports about the problems in the dual system caused by unlicensed packaging and the unfair competition that this entailed. Back in November 2010, EKO-Punkt had already filed a legal complaint prompted by a strong suspicion that quantities were being fiddled. 

Among other things, the FDP MP wanted to know whether “dual systems” and their partners were operating in breach of regulations and how the state government was using the opportunity to adjust quantities in the register of the Association of German Chambers of Industry and Commerce. Another important point requiring clarification was the question of enforcement. Will there be any sanctions against companies which have acted in breach of the Packaging Ordinance?

After all, one third of all packaging – i.e. around two million tonnes – has not been registered for recycling through the dual systems. In a press release, the environmental group, Deutsche Umwelthilfe, voiced concerns about the “disastrous consequences for the conservation of the environment and resources”, which were being “tacitly accepted by the enforcement agencies in most federal states.”

According to estimates made by the Gesellschaft für Verpackungsmarktforschung (Association for Market Research in Packaging), German households produce about 2.2 million tonnes of glass packaging, 1.7 million tonnes of paper packaging and 2 million tonnes of lightweight packaging materials every year. A comparison with the quantities of packaging registered in the dual systems for 2010 shows that around 226,000 tonnes of glass packaging (10 %), 882,000 tonnes of paper packaging (51 %) and 925,000 tonnes of lightweight packaging (46 %) have obviously not been licensed. This means the situation has continued to worsen since 2009. It is high time then that politicians accepted their share of the responsibility. For, the imminent introduction of the new recycling bin is not going to mean an end to the problem. Meanwhile, EKO-Punkt is hoping that its legal complaint concerning fraud with recycling volumes will help improve things. In response to the query, the state government referred to the ongoing procedure, the post-licensing of certain dual systems which has taken place at their request, and the so-called declarations of completeness demanded by LANUV, the North Rhine-Westphalia State Environment Agency. Here the state government criticised the lack of computerised systems for reconciling the declarations of completeness with the reports given to the joint office of the dual systems. Any solution to the problem is, therefore, still a long way off.

The situation regarding the licensing of packaging has once again worsened compared with 2009.

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