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Strategies against the packaging flood

Julia Bernert

Published on 09.12.2022

from PSI Journal 12 / 2022

The amendment to the Packaging Act came into force in the middle of this year. In addition to countless questions regarding the extended obligations regulated in packaging law, the discussion has reignited as to whether and how packaging can become more sustainable. An overview from the editors of PSI Journal.

Tonnes of packaging and plastic waste are flooding the planet. This is no longer ecologically sustainable. The impact on humans and nature is enormous; the disposal of this waste is complex and cost-intensive. The primary goal must therefore be to reduce packaging, and the packaging that does accumulate must be recycled as far as possible or recovered in an environmentally sound, sensible and economical manner. This burden must be shared by all those who put packaged goods into circulation. On the following pages, we explore the question of whether packaging is compatible with sustainability.

Limiting packaging material

Significant facts in the packaging debate are provided by the packaging industry itself, for example through studies, congresses and trade publications. According to these, packaging requires fewer constituents and raw materials, yet annual packaging consumption is increasing. As a current study by the Gesellschaft für Verpackungsmarktforschung (GMV, Society for Packaging Market Research) on the occasion of the 8th Packaging Day (2022) shows, in 2020, 92 percent or 1.6 million tonnes of the consumption-related additional packaging in Germany was saved, in comparison with 1991, through reduced material use. Overall, the material savings through lighter packaging since 1991 amount to 23 million tonnes.

More and more packaging

The fact that packaging use has nevertheless grown over the same period is due to the increased level of consumption and a change in consumer behaviour. If we consumed the same number of products today as we did 30 years ago, we would use 1.7 million tonnes less packaging each year. In addition to the increased number of products consumed, structural effects and socio-demographic factors have also led to an increased demand for packaging material. Aspects such as an increased number of smaller households and the increased demand for smaller package sizes have contributed another 0.9 million tonnes to the increase in packaging consumption. In the sum of increased consumption level, changed consumption structure and minus the efficiency gains through optimised packaging, the private final consumption of packaging across all materials increased by 1.04 million tonnes or 14 per cent to 8.7 million tonnes from 1991 to 2020. Against the background of the repeated statement that no packaging is best and most sustainable, these figures are alarming. The majority of packaging associations are of the opinion that the situation can only be eased by more conscious consumer behaviour and responsible action on the part of the industry.

Packaging is indispensable

To consider packaging solely in terms of resource consumption and environmental damage is not enough, and does not in fact make sense. After all, packaging is a highly functional product that we could not do without: it protects its contents, enables sensitive and liquid products to be transported and thus tradable in the first place, ensures shelf life and hygiene (e.g. in the case of food) and enables compact storage and product-friendly transport. If we consider materials, there is the definite possibility of sustainable alternatives. Taking into account the constraints imposed by the type of goods and the transport route, there is a choice of paper and cardboard, many variations of plastic, composites, glass or metal, as well as filling and insulating materials to protect the goods during transport.

Conscious use of packaging

Whatever we decide to do, we should always ask ourselves this basic question: what do we really need for safe transport and where can we save material and volume? If we choose paper or cardboard packaging, for example, this means: what thicknesses and sizes are really necessary? Is there an alternative to sending a huge cardboard box with a small gift packed in a mountain of bubble wrap? It is a mistake to assume that paper packaging is more sustainable than plastic packaging. After all, the resources consumed in cardboard production are not insignificant, especially when compared to thin, versatile film recyclates. In any case, the raw material, water and energy requirements of the packaging industry are very high, even for recyclates. For example, when paper is recycled, new wood fibres have to be added each time.

High resource consumption

According to the courier-express parcel services study by the Bundesverband Paket und Expresslogistik (Federal Association of Parcel and Express Logistics), the number of parcel, express and courier shipments in Germany alone rose to more than four billion in 2020. More than five billion shipments were forecast for 2025 – this figure will probably already be reached this year. Recycling alone is not enough to reduce resource consumption for these quantities of boxes. The fact that shippers and online retailers repackage packaged goods is an additional step in the packaging chain that is anything but sustainable, especially since the accumulated packaging is immediately destroyed after one-time use. This is also often a common practice in the promotional products industry.

Recycling as a sustainable approach

The Berlin-based start-up SendMePack has developed an interesting product for online shops, brands and private customers. The founders are convinced that reuse is more sustainable than new production and recycling, even if investments are made in compensation projects. Their business model therefore works exclusively with existing resources and thus makes it possible to reduce packaging waste and lower CO2 emissions. For this purpose, used cardboard boxes are re-integrated into the shipping chain in the sense of a circular economy. Customers who send their goods in SendMePacks instead of new cardboard boxes are not only acting sustainably, but are also making a statement with this label by visibly positioning themselves as pioneers in sustainability. The provider also offers marketing aids and information.

Packaging Act creates transparency

One goal of the Packaging Act is to actively address the packaging problem by increasingly holding initial packaging distributors accountable, creating transparency and gradually tightening the requirements for packaging recycling. In the 2019 revision and the 2022 amendment, for example, the recycling quotas were raised in two steps: for glass, waste paper, ferrous metals and aluminium they were raised from 60 to 75 to 90 percent by 2022, for beverage cartons from 60 to 80 percent and for plastics from 36 to 63 percent. In addition, with the amendment of the Packaging Act, extended packaging law obligations apply from 1 July 2022. 

Extended obligations under packaging law

Since 1 July 2022, all companies that commercially place packaged goods on the market in Germany must be registered in the LUCID packaging register. This obligation applies irrespective of the type of packaging, for sales, repackaging and shipping packaging as well as for transport packaging, reusable packaging, industrial packaging and one-way beverage packaging with deposits, etc. In this way, final distributors of service packaging who have delegated their obligations completely to a pre-distributor are also affected: they must also register in the LUCID packaging register. In case of violations, a distribution ban can be imposed.

The entire supply chain in view

A further restriction: electronic marketplaces may only offer goods from traders and sellers on their platforms if they are registered in the LUCID packaging register and fulfil their system participation obligations. In doing so, online traders and platform operators are under an obligation to verify this. The same applies to fulfilment service providers. They, too, must ensure that their clients comply with packaging law obligations. Otherwise they are no longer allowed to offer their services to their clients. In order to make it easier for electronic marketplaces and fulfilment service providers to comply with their verification obligations, the ZSVR provides them and other interested parties with an XML file on a daily basis with the option of a register retrieval.

Consequences for the industry

What does this mean for the promotional products industry? Let’s take a look at the path a product takes along the retail chain. A delivery arrives in Germany. We can assume that the packaging of powerbanks, tools or bags, for example, has already been licensed by the producer or importer. The boxes in which the goods are delivered are considered transport packaging, they do not reach the end consumer and are therefore not subject to the participation obligation. Now the products are resold via the promotional products distributor. The latter now packs parts of the delivery together with other products in new packaging to send to the customer. In this case, this new packaging in this form arrives on the market for the first time and thus has to be licensed as a shipping package, provided it ultimately ends up with the end consumer. The same applies if a distributor repackages the products beforehand in decorative or individually designed packaging. Even if this packaging is used differently for a time, it must also be licensed. Even packaging that has already been used must be licensed by the trader. This obligation is only waived if they can prove that they have already been involved in the system once. Distributors must therefore always be able to prove that packaging has already been licensed. As a general rule, the final distributor in Germany must ensure that the obligations under the VerpackG are met. Whenever it is uncertain whether a product is subject to system participation, it makes sense to record a corresponding argumentation in the product files. This way, in case of doubt, those affected can justify why they have not licensed their product.


Gesellschaft für Verpackungsmarktforschung (GVM, Society for Packaging Market Research): Study from May 2022 on behalf of the Deutsches Verpackungsinstitut e.V. (dvi, German Packaging Institute), the Arbeitsgemeinschaft Verpackung + Umwelt e.V. (AGVU, Association Packaging + Environment), the Fachverband Faltschachtel Industrie e.V. (FFI, Folding Carton Association Industry), the Industrievereinigung Kunststoffverpackungen e.V. (IK, German Association for Plastics Packaging and Films) and the Industrieverband Papier- und Folienverpackungen e.V. (IPV, Paper and Film Packaging Industry Association).

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