"The current draft of the EU Packaging Regulation will present us all with major challenges."

- Diana Uschkoreit -
Diana Uschkoreit has been at the helm of BellandVision since July 2020. She had previously worked at the service company with a focus on recycling for 18 years and held the role of Sales Director. In an interview with Paul M. Müller, she talks about the EU Packaging Regulation, Germany's pioneering role and how costs are developing.

PMM: Ms. Uschkoreit, you have been part of the French Veolia Group since 2022. How are you doing after the integration?
The integration of BellandVision into the Veolia Group was an exciting and very intensive time for everyone involved, which we mastered together with our new Veolia colleagues. The collaboration has gone well so far and we speak the same "recycling language". Right from the start, we were able to jointly initiate promising recycling projects and BellandVision has continued to assert itself as the market leader among the dual systems, even under its new parent company.

PMM: What has changed?
There are many new contacts for day-to-day operations and new processes had to be created. However, nothing has changed for our customers. Our employees are available to answer all questions about the participation of packaging in the dual system in the usual manner.

PMM: Germany was a pioneer in waste separation, collection and recycling with the introduction of the Green Dot in 1992 - is that still the case today after 32 years?
At the beginning of the 1990s, Germany was the first country to introduce extended producer responsibility for packaging. Since then, manufacturers have had to ensure that the packaging they place on the market is collected, sorted and recycled in accordance with legal requirements. And as not every manufacturer can set up their own collection container in front of every household, there are the dual systems that take on these tasks.
Over the last 30 years, the dual system, as well as the entire sorting and recycling infrastructure in this country, has developed continuously and we are able to achieve some of the highest recycling rates in Europe for a wide range of packaging materials. We also regularly receive requests for advice from opinion leaders from abroad who are trying to understand the complexity of our successful model and transfer it to their national structures.

PMM: The Packaging Act has been in force since 2019: what are the lessons learned?
After almost 30 years of the Packaging Ordinance, it was high time to raise packaging recycling in Germany to a higher standard. The higher recycling rates acted as a kind of catalyst for the entire waste disposal and recycling industry and considerable investments were made in the infrastructure. This was also necessary in order to achieve the ambitious recycling rates. What I would like to point out, however: It cannot be right that on the one hand the dual systems are required to achieve recycling rates of 90 percent, but on the other hand their work is thwarted by new legislation. The extension of the deposit obligation, for example, has removed high-quality packaging from the dual systems' volume flow, which makes it considerably more difficult to achieve the recycling rates.

PMM: What has improved?
Thanks to the higher recycling rates, even more resources can be saved and CO2 emissions can be reduced even more than before. In Germany, packaging recycling saves almost 2 million tons of CO2 every year and produces around 4 million tons of secondary raw materials from used packaging, which in turn can be used for new packaging or products. Another advantage is the greater market transparency. The introduction of the Central Agency Packaging Register control authority has significantly increased the number of manufacturers participating in the dual system and created good conditions for fairer competition - also on the part of the dual systems.

PMM: What do other countries do better?
I am convinced that a competitive system, such as the one we have here in Germany, is the most effective and efficient market model for fulfilling producer responsibility. However, the current wording of Section 21 VerpackG also shows that incentives for ecologically sound packaging require a "workaround" in order to achieve the desired steering effect. For this reason, we dual systems have developed a joint model in the form of a recycling fund that is decoupled from competition, which on the one hand implies the advantages of competition and on the other hand also enables incentives to be set in competition, e.g. for recyclable packaging. Accordingly, manufacturers of packaging that is not recyclable would have to pay a contribution into the recycling fund in addition to the license fee. As confirmed by the current Federal Government in a minor interpellation, this incentive model will play a central role in the amendment of Section 21.

PMM: Where will we be in ten years when it comes to packaging?
The Packaging and Packaging Waste Regulation (PPWR) is currently working on a uniform recycling standard for the EU that will affect all of our work over the next 10 years. That's why I only see packaging in my crystal ball that is recyclable or contains recycled materials.

PMM: What will be the biggest challenge for the dual systems this year?
In 2019, the Packaging Act was a major upheaval for the entire industry. In comparison, however, the changes planned in the current draft of the EU Packaging Regulation are much more far-reaching. All market players will face major challenges in the coming years, particularly in the areas of recyclability, the use of recyclates and verification obligations. The timing of the so-called delegated acts, which further specify the individual requirements of the regulation and are only adopted after publication, will increase the pressure on market players. However, we are convinced that we are well positioned to meet these challenges and will master them together with our customers.

PMM: What are the trends of the future?
Current trends are definitely Design4Recycling and the use of recyclates. If you take a look at the current draft of the PPWR, it quickly becomes clear that these two topics could become essential for manufacturers in the future if they want to place packaged products on the market in the EU.

PMM: What about the availability of recyclate when the European law comes into force?
The current draft law stipulates that plastic packaging must contain at least 10 to 35% recyclate from 2030, depending on the application. Our customers are fortunate that we have strong partners behind us and can draw on the largest recycling capacities for plastics.

PMM: Why are there such big differences in the cost of tinplate between Austria and Germany?
It is fundamentally difficult to compare two fundamentally different systems. This is because the price difference for the participation of metal packaging in the national systems is partly due to the different recycling targets in the two countries. While in Austria only 50 percent of metal packaging has to be recycled, in Germany the figure is 90 percent. The higher recycling targets result in greater collection and recycling efforts, which is also reflected in the costs. In view of the positive environmental impact of packaging recycling in Germany and the high recyclability of metal packaging, I believe this is a worthwhile investment.

PMM: How will the cost of disposing of tinplate develop in the future?
As with other packaging materials, this depends on a wide variety of factors, such as the development of logistics and sorting costs or future marketing revenues for secondary raw materials. Looking at the current recycling rates for metal packaging in Germany, the only certainty is that there is not much room for improvement.

Thank you for the interview.

Personal details:
Diana Uschkoreit has been the Managing Director of BellandVision. At the time, she succeeded Thomas Mehl, who retired. Diana Uschkoreit is well known in the industry and is regarded as an expert in her field. Before taking up her post as Managing Director, she worked at BellandVision as Sales Manager and authorized signatory.

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