IK Industrievereinigung Kunststoffverpackungen e.V.
IK
The German Plastics Packaging Industry Association IK is the voice of the manufacturers of plastics packaging and films acting on the German market and represents: - more than 300 member companies - over 80 percent of the market - a branch with 4 Mio t annual production of plastics packaging and films - an industry with more than 14 billion Euros annual sales and over 90.000 employees IK plays a key role as a successful trade organization on national,European and international level
ID: 630544211586-49
Lobbying Activity
Response to EU rules for the calculation and reporting of recycled content in single-use plastic bottles
19 Aug 2025
Although the implementing decision pursuant to Article 6(5) SUPD only concerns single-use beverage bottles, it is of landmark significance for the implementing act pursuant to Article 7(8) PPWR and therefore for the entire plastic packaging market in Europe. Against the backdrop of the mandatory recycled content quotas and the PCR shortage predicted for 2030, the plastic packaging industry has a keen interest in a regulatory framework that improves the investment climate in the recycling sector and reduces the PCR gap as much as possible by 2030. Please find our detailed amendment proposals in the attached statement.
Read full responseResponse to Review of the requirements for packaging and feasibility of measures to prevent packaging waste
7 Feb 2023
For us, the German plastic packaging manufacturers, the proposed regulation offers an opportunity for the sustainable transformation of the entire packaging industry. Our members have invested in the recyclability of their products and stand ready with innovative solutions that combine high material efficiency with high recyclability and the use of recycled materials. In order not to jeopardise the sustainable transformation, the regulation should be adopted before the European Parliament elections in 2024. With our recommendations, we want to contribute to the success of the regulation, especially in economic and ecological terms. Our recommendations and concrete proposals for amendments (see attached position paper) focus on the following sections: - Recyclability of packaging (Article 6) - Minimum recycled content quotas for plastic packaging (Article 7) - Compostable packaging (Article 8) - Packaging minimisation and ban of excessive-packaging (Articles 9 and 21) - Obligation to reuse packaging (Article 26) - Product bans (Article 22)
Read full responseResponse to Measures to reduce microplastic pollution
18 Jan 2022
Regarding the initiative “Measures aiming to reduce the presence in the environment of unintentionally released microplastics from tyres, textiles and plastic pellets”, IK (the German Association for Plastics Packaging and Films) provides the following information and comments:
Quantities and sources of plastic pellet emissions into the environment
For this purpose, the BKV report " Plastics in the environment in Germany" should be taken into account, which deals with the analysis of all inputs of plastic litter from Germany into soils, inland waters and oceans. (https://www.bkv-gmbh.de/studien/bericht-kunststoffe-in-der-umwelt.html). The latest version of April 2021 takes into account all relevant publications that have been published so far in Germany
Effects of microplastics on human health
The German Federal Institute for Risk Assessment comes under the portfolio of the Federal Ministry of Food and Agriculture for all scientific aspects of consumer health protection. Please find some publications on the topic of microplastics here:
https://www.bfr.bund.de/de/a-z_index/mikroplastik-192184.html
Effects of microplastics for the environment
IK is member of the “Round Table on Marine Litter” in Germany. It consists of around 130 experts, e.g. from fishing, shipping, industry (plastics, cosmetics, tyres), retail, science, education, tourism, environmental associations, authorities, politics and art. A subgroup of this initiative also deals with the effects of microplastics to the environment. All further information can be found by following this link: https://www.muell-im-meer.de/
Measures for consideration for plastic pellet losses:
Due to our field of activity, we can only comment on the planned measures for plastic pellets.
We support the idea by the European Commission to further develop the existing voluntary approaches. In the past year, the plastics producers and the plastics converters collaborated very intensively on the further development of the Operation Clean Sweep (OCS) programme. The OCS programme will be expanded in 2022 to include a certification system for the entire supply chain that provides a framework with concrete measures for the respective companies, which can then be verified in independent third-party audits. The training of staff will be one of 6 core requirements.
There is a lot of experience on best practice examples for pellet retainment measures at operation sides that are being available by OCS (https://www.opcleansweep.eu/).
However, the effectiveness and cost efficiency of measures vary widely. The legal measures should therefore be appropriate, practical and proportionate, especially for small and medium-sized companies in the plastics converting industry. It is therefore important to support any measures by a thorough impact assessment.
Bad Homburg, 18.01.2021
Read full response13 Jan 2022
We, the German Plastic Packaging Association (IK), comment on the Commission's draft in abbreviated form as follows. Attached is our regular statement.
1. Impact assessment for proposal is necessary
We call on the Commission to analyse, in particular, the impact of the new rules on the availability of recycled plastics for use in food packaging, their price, the effort required to comply with the new rules and the competitiveness of companies in the relevant value chain.
2. Implement authorisation procedures
We call on the Commission to explain why the proposed authorisation process, which essentially corresponds to the current, ineffective procedure, should actually lead to authorisations in the future. The Commission should also quickly authorise the more than 200 recycling processes (mainly for PET) that have been assessed as safe by EFSA, even before the new regulations come into force.
3. Expand, not restrict, the possible uses of recyclates:
a. Post-industrial recyclates (PIR) are necessary for the circular economy
We recommend either explicitly excluding PIR from the scope of the proposal (thus continuing the current legal situation) or explicitly classifying PIR as a "suitable recycling technology" for the production of food contact materials and allowing it without an individual authorisation, provided that the requirements of Regulations 10/2011 and GMP Regulation 2023/2006 are met.
b. Supplement regulation on functional barriers
An exemption for recycled plastics behind a functional barrier is - as today - necessary to increase the share of recyclates in food contact materials while guaranteeing consumer safety.
c. Insert clarification on chemical recycling
We recommend clarifying that for plastics that are the result of a chemical recycling process, the requirements of this Regulation do not apply, but only the requirements of Regulation 10/2011 apply.
d. Make provision for mechanical, solvent-based recycling processes
We recommend that mechanical, solvent-based recycling processes be explicitly classified as "suitable recycling technology" for the production of food contact materials, provided that the requirements of Regulations 10/2011 and GMP Regulation 2023/2006 are met.
4. Expand PET recycling, don't restrict it
We recommend that a recycling process that has been assessed as safe by EFSA should be authorised by the Commission in a timely manner or be usable as a "suitable recycling technology" without individual authorisation. We als recommend that also those mechanical PET recycling processes that use a higher share than 5% of non-food contact materials and are assessed as safe by EFSA can be classified as "suitable recycling technology".
5. Don´t jeopardise safe processes through an overcautious approach
PET recycling processes assessed as safe by EFSA have proven themselves in practice for many years without any indication of health risks. We therefore call on the Commission to explain what health reasons there are to justify stricter and, above all, much more bureaucratic regulations regarding the use of recyclates in food contact materials.
6. Coherence with waste legislation required
It must be ensured that the regulatory starting point for the use of recyclates continues to be the successful completion of a recycling process that has been assessed as safe (“end of waste”). Deviating requirements, such as the proposal for a "decontamination process", make the already complex legal situation even more complicated and prevent the increased use of recyclates.
7. Designing closed-loop recycling in a practical way
8. Labelling of recyclates is superfluous bureaucracy
9. Marking hinders recycling
10. Design regulations on "Novel Technologies" in an innovation-friendly way
11. Avoid discrimination against plastics and transition solution
12. Adapt proposal to legal basis
Some proposals exceed the authorisation for specific measures granted by Article 5 of Regulation 1935/2004.
Read full responseResponse to Review of the requirements for packaging and feasibility of measures to prevent packaging waste
6 Aug 2020
IK represents the plastic converting industry in Germany in the field of plastic packaging production with about 300 member companies, mostly SMEs. The branch produces a revenue of 15 bn Euro and employs about 90,000 people.
We welcome the European Commission's goals of climate neutrality and a circular economy as laid down in the Green Deal. Under the conditions of climate neutrality, which the EU is aiming for the year 2050, high-quality recyclates will have to make a significant contribution to securing the supply of raw materials to the plastics industry. The shift towards a Circular Economy is therefore a key challenge for our industry and governments.
With regard to the Commission’s initiative to review the requirements for packaging and other measures to prevent packaging waste, we would like to highlight the following aspects:
• We appreciate the objective of creating harmonised rules on packaging in order to increase long-term planning certainty for packaging related investments, especially in the field of circular economy, and avoid uncoordinated national measures which pose obstacles the free movement of goods and hinder the development of well-functioning markets for secondary raw materials.
• We emphasise that packaging must be seen as an integral part of a packed product. Measures aiming at reducing packaging waste must therefore take into account the packaging’s functionalities. Adverse effects of reduced packaging like increased product waste or energy use (e.g. for changed logistics and cooling) must be avoided and examined as part of in the impact assessment.
• Reusable packaging is not necessarily advantageous for the environment compared to single-use alternatives. That is mainly due to the increased energy consumption for logistics and transport when returning the packaging and preparing it for reuse. Branded reusable packaging is particularly problematic in this context because it must be returned to a specific brand owner (as opposed to pool systems shared by the various fillers). Furthermore, a high return rate is crucial for the environmental performance of returnable packaging, that has to be incentivised by a high deposit. We recommend recent studies by BGVZ on the German beverage packaging market.
• Any targets and measures must be of general nature, not specific for certain materials or formats, in order to preserve fair competition for the best solution and avoid adverse environmental effects through substitution.
• Last but not least, we urge the Commission not to over-regulate, especially by imposing market restrictions and detailed design requirements. The regulatory measures must be reduced to the necessary level needed for achieving the overall objectives of climate neutrality and circular economy and leave the greatest possible scope for entrepreneurial inventiveness and innovative solutions.
Please find attached the joint statement of the plastics packaging industry in France and Germany on the Circular Economy Action Plan which contains more details on the proposed measures. We welcome every opportunity to deepen these points in a personal conversation.
Read full responseResponse to A new Circular Economy Action Plan
20 Jan 2020
IK welcomes the roadmap for a New Circular Economy Action Plan.
Circular Economy is a central challenge for industry and governments. All those involved in the plastics value chain, including consumers, must make their contribution to ensuring that plastics can be recycled with the highest possible quality and without material losses. Our association therefore aims to increase the proportion of recyclable or reusable household packaging on the market from the current 75% to at least 90% by 2025 and to increase the use of recycled materials in the production of plastic packaging from 400,000 tonnes to 1 million tonnes.
We would welcome if the following aspects could be considered by the Commission in the New Circular Economy Action Plan:
1. A priority must be the development of functioning markets for recycled plastic materials that can provide the quantities and qualities required by the plastics converting industry, without compromising on product quality and consumer safety. This must be based on sound market mechanisms.
2. In addition to design for circularity, better separate collection of plastic packaging is the key to increasing the circular economy. We therefore call on the Commission to set ambitious targets for the separate collection of plastic waste and to speed up the phasing out of landfill.
3. Under the conditions of climate neutrality, plastics made from renewable raw materials will gain in importance alongside recycled materials. IK therefore calls on the Commission to define the framework conditions for sustainable production and use of bio-based plastics at an early stage in order to avoid adverse effects on the environment and land use conflicts.
4. As a contribution to the announced strategy for sustainable products, the IK draws attention to the Management Guidelines of the Round Table Eco Design of Plastic Packaging, which were developed by experts from the entire supply chain: https://ecodesign-packaging.org/en/
About IK:
IK Industrievereinigung Kunststoffverpackungen e. V. is the trade association representing the interests of manufacturers of plastic packaging and films in Germany. The industry, which is characterised by medium-sized companies, has more than 90,000 employees and generates an annual turnover of 15 billion euros. With an annual production of 4.5 million tons, Germany accounts for approximately 22% of the European production of plastics packaging.
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