DPG provides additional food for thought
The draft of a European-wide binding packaging wate directive (PPWR) presented by the EU Commission in November 2022 - we reported in the article of 15.12.2022 - has stimulated an intensive discussion about the future of packaging market regulation. The DPG has also taken a position in an official statement.

Four core demands
Until 10.5.2023, concrete amendments to the current proposal of the new Packaging Waste Directive (PPWR) could be submitted to the Committee on the Environment, Public Health and Food Safety (ENVI) in the European Parliament.

Based on its statement of 30 March 2023 (in german only), the DPG, together with its shareholders, has drawn up detailed proposals for amendments to individual points of the PPWR and submitted them to the responsible members of parliament. All of the German stakeholders involved welcome the fact that the EU Commission recognises deposit and return systems in principle and explicitly as essential measures to ensure sustainable material cycles.

Nevertheless, the DPG and its partners see a clear need for improvement in four core areas of the current draft text. In order to protect the correct and important EU initiative from possible ecological setbacks, but also in order not to unnecessarily restrict the performance of existing systems and in order to maintain the recyclability of raw materials in the sense of a successful circular economy1 the following aspects in particular should be given legislative consideration:

  • Retention of national, established identification marks. In order to continue to smoothly guarantee the existing orientation of consumers, but also important safety aspects around the reading technology as well as reliable deposit clearing, introduced identification marks such as the DPG deposit logo, which functions as a central safety element in the German deposit system, must be retained. Furthermore, an additional deposit logo valid throughout Europe is quite conceivable.
  • Defining a lower limit for disposable beverage packaging. In accordance with the recommendations of the Impact Assessment Report, the handling of certain filling volumes of packaging (e.g. small packaging) should remain regulated at national level depending on the respective framework conditions.
  • Clear grandfathering rules. In order to hedge achievements and to be able to benefit from existing best practice experiences, binding grandfathering rules must be developed for high-performance system operators and ecologically exemplary systems.
  • Adaptation of some minimum requirements as formulated in particular in Annex X of the PPWR. In this context, the DPG and its associates have drawn up clear proposals for improving the draft texts and presented them with detailed reasons.

With 88 members, the ENVI Committee is currently the largest committee of the European Parliament. With the statement of the DPG and its shareholders, the political discussion within this body and far beyond is to be further advanced and enriched by the aforementioned aspects, which are also relevant to competition. A statement by ENVI is expected in October of this year.

The DPG and its shareholders are convinced that the interoperability of existing and new EU deposit systems, in particular, will pose special challenges for the EU member states with regard to crossborder economic traffic. In order to make good progress here and to create internationally sustainable framework conditions, the ecological successes and the experience of established closed-loop systems should be used in the best possible way.

With more than 20 billion disposable beverage packaging per year, more than 50,000 reverse vending machines and return rates of more than 98%2, the DPG, as a privately financed non-profit organisation and operator of the German deposit system, achieves true top values within the European Union. We are pleased about the many international enquiries and visitors who like to come in person and learn more about the almost 20 years of lived practice and the perspectives of many different system participants and get information from us.


1 GVM-Study „Materialeffizienz von Packstoffen im Vergleich“, May 2023, Publisher GVM Gesellschaft für Verpackungsmarktforschung 
GVM-Study „Aufkommen und Verwertung von PET-Getränkeflaschen in Deutschland 2019“, October 2020, Publisher GVM Gesellschaft für Verpackungsmarktforschung, abrufbar unter https://dpg-pfandsystem.de/images/pdf/2020-10-19-Kurzfassung-Verwertung-PET-Getraenkeflaschen-2019.pdf

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