Mehrwegverband Deutschland e.V.
Ziel des Mehrwegverbandes Deutschland e.V.
ID: 339222049417-87
Lobbying Activity
Response to Review of the requirements for packaging and feasibility of measures to prevent packaging waste
6 Apr 2023
The German Association for Reusable Packaging (Mehrwegverband Deutschland e.V.) is non-profit organisation founded in 2022 and consists of 70 members, mainly companies and organisations that - are system operators of reusable packaging solutions for food, E-commerce, take-away or body- and homecare articles, - fill food, body- and homecare and other products in reusable packaging, - investigate or research and/or consult the topic of reusables, and - offer solutions in material selection, design, cleaning, logistics or sorting. Our common goal: avoid packaging waste and close material cycles to not lose valuable materials and resources. The clear focus of the association is on reusable packaging systems (in German Mehrwegsysteme) Our position at a glance: The obligation to offer reusable packaging for take-away food as part of the amendment of the German Packaging Act ("Mehrwegangebotspflicht) in place since 1st January 2023 proves that legislation can significantly support innovative solutions and the necessary infrastructure to reduce packaging. Above all, formulating clear targets and necessary framework conditions while avoiding over-regulation, supports innovation and provides investment security. The German Association for Reusable Packaging therefore considers the proposal to amend the Directive (94/62/EC) on packaging and packaging waste, first issued in 1994, and its transformation into a regulation as an important initiative for a sustainable change in the packaging industry. The German Association for Reusable Packaging particularly welcomes the fact that the draft contains reuse as an option for packaging, including concrete targets. At the same time, the steering effect in the current draft is limited by essential points. The German Association for Reusable Packaging therefore proposes: - The clear and appropriate use of definitions of terms for reusable packaging, including a clear differentiation between reusable packaging or systems and refillable items in consumer possession ("bring your own" or "refill"), as well as the use of the wide used and common term "Mehrweg" in the German version of the Regulation; - A realistic (practice oriented) description of reusable systems, replacing the currently inadequate and inaccurate distinction between "open and closed loop systems" in Annex VI of the draft regulation; - A clear distinction of the concepts of reusable packaging and refilling in the targets as laid down in Art. 26, an increase of the target for take-away/ready-prepared food, intended for immediate consumption, as well as the introduction of targets for other FMCG product groups; - The exception of reusable packaging already in use as regards the specified minimum recycled content for packaging as laid down in Art. 7, as well as temporary exemptions for newly reusable packaging placed on the market, in case there are insufficient quantities of recycled material available on the market; - To state explicitly the option for Member States to set more ambitious targets than those set out in the Regulation - e.g. to be allowed to set higher reusable targets; - Not to include a mandatory obligation for the introduction of serialised labelling of reusable packaging, as it can be read from Art. 11(2) and (4); - Include a clearly regulated, general take-back obligation for reusable packaging The German Association for Reusable Packaging is ready to support the EC constructively and in the sense of sustainability in the revision of the draft legislation and to share collected, published studies and reports, as well as practical experience from existing and emerging reusable systems. Thank you very much for the attention with which the proposals are certainly handled. We wish success in revising this important and groundbreaking legislation.
Read full responseMeeting with Malte Gallée (Member of the European Parliament) and Ecopreneur.eu and Werner & Mertz
23 Mar 2023 · Packaging and Packaging Waste