The wrangling over the new requirements of German packaging regulations [VerpackVO] seems to be drawing to a close. In September 2007, the Federal Cabinet approved a proposal to this effect. The measure was debated in the Parliamentary Committee on the Environment on 10.10.2007. The Dairy Industry Association [MIV] played an active part in defining a common position together with other major associations (industry and retail). The general tenor was that it would surely be more efficient to evaluate all measures relating to rubbish disposal and recycling as a whole, although this is politically impossible at the moment. Given this, the current regulations must be adjusted so as to maintain fair competition and legal clarity. For this reason, the proposed amendment is a good thing.

The key points of the new regulations are:

• A strict separation of household/recycling systems and self-disposal. This means that all rubbish produced by households will now only be disposed of through dual systems (rubbish separation), but trade waste may be self-disposed. The previous bogus methods that seriously threatened the existence of dual systems are therefore eliminated.

• Through completeness statements on the part of licensees and a clearing bureau for waste disposal services, control of the actual licensing of packaging brought into circulation will be significantly improved and tightened up.


• Which packaging requires licensing and in what form will be determined by a system depending on the size of the packaging. This means that above a certain size of trading unit, there will no longer be an assumption of use in a domestic context, so there will be no requirement for licensing for dual systems. Even so, there will certainly still be some borderline cases. This regulation had already been discussed and favourably received in the Milk Industry Association's working group on procurement.

• The new rules are planned to come into effect at the end of the year. However, there will be long transitional periods, so the actual effects of the new regulations will probably not be seen until the end of 2008 at the earliest. Nonetheless, the amendment should be seen as clearly putting to an end the freeloading and unjustified advantages [of some] compared to honest licence fee payers.

• The decision of December 2004 to exempt milk drinks from the compulsory bottle deposit remains unchanged.