An updated version of the "Minimum standard for the assessment of the recyclability of packaging subject to system participation pursuant to Section 21 (3) of the German Packaging Act", in short the Minimum Standard, is published annually on September 1st. We have summarised the essential changes for you as below.
In the draft for the consultation procedure of the Minimum Standard, the "existence of a recycling infrastructure via fraction numbers" was to be rated as "marginal" for almost all flexible packaging. Instead, the Minimum Standard stipulates that individual evidence of high-quality recycling must be provided in order for packaging of these material fractions to be classified as recyclable by the dual systems. Since the availability of itemised proof depends on the capacity utilisation of the recycling plants, incalculable consequences for distributors would have been the result. Not least due to massive objections from industry during the consultation process, this adjustment is no longer included in the final version of the Minimum Standard for the time being. This means that in Germany flexible packaging made of PE and PP can continue to be classified as recyclable without individual proof, regardless of its size.
In "Annex 3: Overview of packaging fractions/types and material-specific recycling incompatibilities" of the Minimum Standard, the essential change with regard to flexible packaging can be found.
(Source: Mindeststandard 2023, page 33)
The recycling impurities of packaging films were previously combined in one fraction "film and LDPE". This has now been divided into two categories: "PE films > DIN A4" and "PE-flex < DIN A4 and PP-flex".
With regard to the negative assessment of NC-based ink systems in sandwich-printing, it can be assumed that this will also be transferred to the formats < DIN A4 next year, as printing inks cause significant impairments in recycling. In order to take these developments into account, we have been active for some years in various cooperation projects on topics such as de-inking and the use of alternative ink systems.
If you have any questions on these or other topics, please do not hesitate to contact us.