Packaging: New Draft Law Published in Germany

The German Federal Ministry of Environment (BMUB) is currently working on a draft for a new Packaging Law, which will repeal the Packaging Ordinance. Besides some new definitions which are intended to clarify terms of the law and higher collection and recycling targets, the current draft foresees some major changes in how the system for packaging will be administered in future:

The draft contains the set-up of a central authority (similar to the function of stiftung ear, the German WEEE producer register). It will manage the newly demanded registration for packaging in Germany and will be in charge to administer a Declaration of Completeness.
Impact on producer obligations

With the numerous changes proposed, producers will have to face new requirements, such as registration in the public register for packaging with the new central authority and submission of an annual Declaration of Completeness – even producers who do not meet the current annual thresholds for such declaration will have this obligation in future. Furthermore, the pricing structure of recycling fees will change, as the draft foresees fees based on recyclability of packaging.

A final draft of the law is not expected before early 2017.

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