Take-back of industrial packaging in Germany

Implementation of the German Packaging Act (VerpackG) at Wacker Chemie AG

According to the German “Act on the Placing on the Market, Take-Back and Recycling of Packaging” (“Packaging Act – VerpackG”), manufacturers and subsequent distributors of packaged goods in the supply chain are obliged to take back and recycle packaging materials after use.

Contact

Manufacturer in this context refers to the company that first brings the packaging into circulation on the German market for commercial purposes.

The German Packaging Act makes a fundamental distinction between packaging subject to system participation and packaging not subject to system participation .

Packaging subject to system participation typically accumulates in private households and can be disposed of via municipal waste disposal services or the dual system.

Packaging not subject to system participation , e.g., packaging of a purely commercial nature, packaging incompatible with the system, and packaging containing hazardous substances, does not fall within the scope of municipal waste disposal services.
In such cases, the manufacturer and distributor are deemed as the “initial distributor” and are responsible for ensuring proper take-back and recycling.

Commissioned third parties

Third parties may be commissioned in order to comply with the take-back and recycling obligation and meet the requirements of the Packaging Act.

Depending on the type and size of the packaging, recycling companies, companies in the reconditioning (reusable packaging) business, or the manufacturer of the packaging shall be responsible for taking back used packaging.

Legal obligations of consumers (producers of used packaging)

Though the Packaging Act has regulated the take-back obligation for manufacturers and distributors, it has not stipulated a return obligation on the consumer, i.e., the producer of used packaging. This implies that our customers are free to choose whether or not they wish to avail themselves of take-back facilities and services. The consumer, i.e., waste owner, shall nonetheless be responsible for selecting the proper disposal method.

This website has compiled a list of the take-back systems available for the nationwide take-back and recycling of industrial packaging.
Our aim is to offer our customers efficient disposal methods that ensure the responsible handling of used packaging.
The careful handling of hazardous substances and dangerous goods plays a vital role in conserving global resources and ensuring the safety of the population. We therefore ask you, our customers, to use the disposal methods listed on this website whenever possible.

Basic take-back conditions and important information

When returning packaging, the following conditions must be met regardless of the type and size of the packaging. The industrial/commercial producer of the used packaging shall be responsible for complying with this provision.

The packaging must be completely emptied, i.e., its contents must have been used up entirely for the intended purpose. As a result, it must be emptied such that it is free of residue from scraping, dripping, and pouring. Furthermore, care should be taken to ensure that no residues are present that could be released into the environment.
No residues of the contents may adhere to the outside of the packaging.
Packaging equipped with closures or sealing mechanisms must be properly sealed.
The packaging must bear the product label and, if applicable, the hazardous goods label of the latest contents. Labels should be clearly legible and fully visible. The safety data sheets of the latest contents must be provided on request.
No foreign materials or contaminants may be filled in the packaging.

Packaging that was used to provide hazardous and non-hazardous contents will be taken back, provided that it is not subject to the system participation requirement.
Packaging used for explosive or radioactive materials will not be taken back.

Additional exceptions are expressly stipulated in the take-back solutions.

All take-back partners require a delivery, acceptance, or packaging return report that serves as documentation for their volume flow records.

In addition, the take-back conditions of the respective take-back system must be observed.

Unless otherwise agreed, take-back partners may reject industrial packaging that fails to meet the take-back requirements specified above.
Exceptions may be granted in special cases.

Reconditionable and non-reconditionable packaging

Packaging that is not subject to system participation is categorized into reconditionable (reusable) and non-reconditionable (recyclable) packaging.

The different types of packaging belonging to the two categories are as follows:

Reconditionable packaging

Combi IBCs
Wooden pallets
200-liter PE and steel containers

Non-reconditionable packaging

Steel and tinplate containers < 200 liters
Paper bags
Cardboard and corrugated cardboard
Films, flexible intermediate bulk containers (big-bags), PE containers < 200 liters, fiber drums, composite packaging

Reconditionable packaging

As described earlier, reconditionable packaging includes combi IBCs , 200-liter PE and steel containers , and wooden pallets . These types of packaging are mostly taken back by manufacturers or specialist reconditioning companies.

These members of the reconditioning industry are committed to sustainable and environmentally friendly business practices and the responsible handling of packaging and any filling material residues.

Additional take-back conditions

In addition to the general take-back conditions mentioned above, the following conditions too, where applicable, must be met for reconditionable packaging:

The packaging should not be severely deformed or damaged.
All containers must be transported in an upright position with the opening facing the top.
No foreign materials or contaminants may be filled in the packaging.
The containers must be sealed after emptying or pretreatment.
Prerinsed or neutralized containers must be labeled appropriately.
The safety data sheets of the latest contents must be provided on request.
Labeling (e.g., product label) must correspond to the latest contents and may not be removed.
Inliners must be removed.

Charges

Revenue/charges are to be agreed upon and settled between the consumer (i.e., producer of used packaging) and the reconditioning service provider.

Contacts

Combi IBCs

As per return/take-back note or information on Combi-IBC

Plastic and steel packaging > 200 liters

VDF – Verband der deutschen Fass- und Industrieverpackungsrekonditionierung e.V. ( https://www.vdf-net.de/)
Tel. +49 (0) 2 11 / 4 54 65 24
info@vdf-net.de
VMS – Verpackungsrücknahme mit System. e.V. ( http://www.verpackungsruecknahme.de/)
Tel. +49 (0) 2131/272999
info@verpackungsruecknahme.de
VIV – Verwertungsgemeinschaft Industrieverpackungen ( https://www.viv-net.de/)
Tel. (0 40) 7 31 06 70
Fax (0 40) 7 32 17 96
info@viv-net.de

Pallets

HPE – Bundesverband Holzpackmittel, Paletten, Exportverpackungen e.V. (Federal Association for Wooden Packaging, Pallets, and Export Packaging) ( https://www.hpe.de/)

Non-reconditionable packaging

As mentioned above, the non-reconditionable packaging category includes small steel and PE containers with a capacity of less than 200 liters , fiber drums , big-bags , miscellaneous plastic packaging , paper bags andcorrugated cardboard packaging .

Small steel and tinplate containers < 200 liters

WACKER has commissioned service provider KBS to take back packaging that belongs to this category. All packaging that bears the relevant logo can be returned via this provider.

Paper bags

WACKER has commissioned service provider Interzero Repasack GmbH to take back packaging that belongs to this category. All packaging that meets the conditions listed below for returning can be returned via this provider.

Cardboard and corrugated cardboard

The return and recycling of packaging in this category is guaranteed by the “Organisation für Wertstoffentsorgung” (Organization for Recycling), or RESY (for Recycling System) for short. Our cardboard manufacturers are licensees of the RESY symbol.

Big-bags, films and plastic containers < 200 liters

WACKER has commissioned service provider RIGK to take back packaging in these categories. All packaging in the categories listed below can be returned and recycled regardless of whether it bears a label, logo or symbol provided by RIGK.