Packaging Ordinance: Tradespeople want practical rules

As the consultation period for the implementing act on extended producer responsibility of the EU Packaging Regulation comes to an end, the ZDH is advocating for changes to avoid overburdening businesses.

At the end of the consultation period for the implementing act on extended producer responsibility of the European Packaging Regulation, which has been in force since mid-August, the Secretary General of the Central Association of German Crafts (ZDH), Holger Schwannecke, calls for regulations that are also feasible for businesses in practice.

The regulation's goal of reducing packaging waste is correct. However, it is problematic that the extended producer responsibility (EPR) does not clearly distinguish between producers and manufacturers. "In its current form, the packaging regulation treats bakeries like manufacturers when it actually concerns the distribution of bread bags, cake packaging, and takeaway coffee cups," says Schwannecke.

Making the packaging regulation more practical

Holger Schwannecke Photo: © ZDH / Schuerring

Bakeries did not produce this packaging, but used it for selling their products. Schwannecke: "The Commission is called upon to design the regulations on the Packaging Ordinance in a practical and proportionate manner. We need effective de minimis thresholds below which businesses are exempt from the EPR obligations."

A possible annual limit would be around 1.000 kilograms of packaging material. "Furthermore, companies should be able to report their EU deliveries to national systems. These could then automatically transfer the data to a standardized EU-wide reporting portal. Appointing an authorized representative must remain voluntary."

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Risks for businesses

The reporting and registration obligations associated with the EPR are also problematic. "Craft businesses, especially those near borders, could be excluded from the internal market. For the primarily affected micro and small businesses, the costs and bureaucratic burden are disproportionate to the potential benefits. The current implementing act for the Packaging Ordinance must not be adopted until there is legal certainty regarding the EPR. Anything else would be irresponsible."

Source: ZDH

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