Der Grüne Punkt - 02. September 2020

Prevent tax concessions for production waste!

Der Grüne Punkt, Werner & Mertz, a producer of detergents and cleaning agents, and the German Nature and Biodiversity Conservation Union (NABU) demand a uniform definition for plastic recyclates

Berlin, Cologne, Mainz, 2 September 2020. During the decade ahead, the issue of the circular economy will be one of the paramount tasks, if not THE key priority in environmental policy-making. But in contrast to paper and glass, only a much smaller percentage of plastic is as yet being recycled and then used to make new products: the EU Packaging Directive stipulates that by 2025 50 percent of all plastic packages in the EU be recycled. Moreover, since it will in future no longer be permitted to include processing losses when calculating the recycling quota, this means that the recycling volume of plastic packages will over the next few years have to be almost doubled throughout Europe, from its current approximately 4.6 million tons to about eight million tons. So huge efforts are required here, plus unambiguous political framework conditions, so as to both protect our natural environment and economize on raw-material consumption by means of appropriate plastics recycling.

The low recycling quota is above all attributable to the fact that it is considerably cheaper to use new merchandise than to utilize recyclates – this cost difference has increased even more in the wake of the economic consequences entailed by the coronavirus crisis: with the decline of the crude-oil price, recycling quotas have likewise been falling drastically. According to a current survey conducted by the BDE (Federation of German Waste Management Companies), demand for recyclates from producers of plastic packages has decreased by 30 %.

For this reason, there is no way round financial assistance for packages made in whole or in part of recyclates. That has been laid down in the packaging legislation in force since 2019, and it is likewise the approach reflected in what is called the “Plastic Tax” on non-recycled plastic, approved by the EU and to be introduced as of 1 January 2021. What is of crucial importance in this context, however, is a clear definition of the term “recyclate”: when statutory regulations specify minimum quotas for the recyclate content in packages, or when the use of recyclates is to be incentivized by providing financial assistance, the definition of what such regulations refer to must be correspondingly unambiguous and laid down in the impending amendment of the Product Recycling and Waste Management Act.

One of the prerequisites for a genuine circular economy is that any waste discarded by end users is recycled for high-grade re-use in new products. The recovery of production waste, also known as “post-industrial recyclate”, by contrast, does not help in countering plastic littering on our planet.

This is why Der Grüne Punkt, the Werner & Mertz GmbH company (whose products include the Frosch brand) and the German Nature and Biodiversity Conservation Union (NABU) demand that a legally binding definition for plastic recyclates be drawn up, which gives post-consumer recyclates (PCRs) clear preference in qualifying for subsidies. Post-industrial recyclates, by contrast, should not qualify for subsidies, nor should they be included in the calculation of future minimum quotas for recyclate contents in packaging.

For when post-industrial plastic waste is likewise subsumed under the term “recyclate”, many companies could choose this simpler and cheaper option, as Reinhard Schneider, a managing shareholder at Werner & Mertz GmbH, points out: “In our pioneering role, we have paved the way for top-quality use of PCRs from the Yellow Sack, and we know that the marketable solutions we have developed will not become more widely accepted when post-industrial recyclates are in terms of environmental protection erroneously treated as equally valuable. It is substantially cheaper to process post-industrial waste, which is ultimately the result of inefficient processes. And in no way should these be subsidized by the government. Consumers quite rightfully expect sustainable solutions here, no tricks.”

Jörg-Andreas Krüger, the NABU’s President, emphasizes just how important recycling is for environmental protection: “To protect the climate and economize on raw-material consumption, we shall have to minimise our packaging outlay and recycle plastics in tightly defined loops. What’s needed in this context is manufacturers keen to adopt recycling-friendly design, who are using recycling material in high-grade applications. But all too often, companies are dressing up their recycling successes by merely recovering their production residues, thus failing to assume genuine product responsibility. To make sure that more investment is channelled into the technically challenging recycling process for waste from the Yellow Sack, the legislator must provide special incentives to promote recovery of these waste flows and introduce a legally binding definition for plastic recyclates.”

Michael Wiener, CEO of Der Grüne Punkt, even goes one step further, highlighting the fact that the entire circular economy depends on the correct definition: “We shall only be able to solve the plastics crisis if plastic becomes truly recyclable. To this end, we will have to access precisely the plastic waste originating at the end user, the recycling of which constitutes a genuine challenge. Recycling of post-industrial waste doesn’t need subsidies – but recycling of post-consumer waste most definitely does. For this reason, it is of vital importance that a differentiation be made here – and this differentiation will be crucial in determining whether the circular economy for plastics will succeed or fail.”

All three of them concur that only a clear, unambiguous definition of the term “recyclates” can save the circular economy and thus protect both the climate and our natural environment. Proof of origin could be provided by means of the RAL Quality Mark for “% of recycled plastic”, stating the percentage of recycled plastic materials from the Yellow Sack or Yellow Bin contained in the product in question. The recovery of commercial and post-industrial waste is explicitly not incorporated in this percentage, so as to create some purposeful incentives for re-using plastic materials obtained from household waste.

Your contact person at NABU: Sascha Roth,, +49 30 284 984-1660

NABU: The German Nature and Biodiversity Conservation Union (NABU) has been showing commitment to humankind and nature ever since 1899. With over 770,000 members and sponsors, the NABU is the largest environmental association in Germany. Its principal tasks include the preservation of habitats and biodiversity, the promotion of sustainability in agriculture, forest management and water supply and distribution, as well as climate protection. Helping people to discover nature and to acquire some knowledge of flora and fauna is among the NABU’s central concerns. Practical nature conservation, lobbying, environmental education, research and public relations are all of them crucial elements in the work of the approximately 2,000 NABU groups and the roughly 70 information centers distributed all over Germany.

Your contact person at Der Grüne Punkt: Norbert Völl, Tel.: +49 22 03 / 937-507

About the Der Grüne Punkt Group: The companies of Der Grüne Punkt are service providers for extended producer responsibility, leading suppliers of secondary raw materials for plastics, and premium producers of plastic recyclates, and as such positioned as the premier solution providers for the needs of the circular economy. Der Grüne Punkt – Duales System Deutschland GmbH (DSD), with the Green Dot as its trademark, was among the companies to introduce and establish the dual system in Germany, and stands for intelligent take-back systems, plus the development and marketing of innovative recyclates and services. Systec Plastics, at its facilities in Eisfeld and Hörstel, produces premium-quality recyclates under the Systalen brand name for the international market. The companies are grouped together in DSD – Duales System Holding GmbH & Co. KG.

Your contact person at Werner & Mertz: Birgitta Schenz,, +49 6131 964 2028

Werner & Mertz: Werner & Mertz GmbH has been located in Mainz for more than 150 years now, and firmly established on the European market as an innovative company with its Frosch, Erdal and green care Professional brands. The firm is operating on the principle of eco-friendly sustainability, which it regards as one of its proactively embraced company traditions. With the Frosch initiative and selective project partnerships, Werner & Mertz is paving the way for sustainable, up-to-the-future solutions, thus mapping out important pointers way beyond its own sector.

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