Implementation of the Packaging Act (VerpackG)
Support for municipalities for the Coordination Agreement and analyses
Points of the new provisions of the Packaging Act (VerpackG) that are important for municipalities come into force on 01.01.2019. A large number of municipalities will be required to make agreements for the period of performance from 2019 in 2018.
Although some aspects for specific negotiations are still open, several public waste management organisations (örE) will take preparatory measures and hold discussions for the Coordination Agreements in the coming months. Open aspects are, for example, methodology issues in determining the volume fractions of PPK (paper/paperboard/cardboard) sales packagings or the assignment of the joint representative of the "Dual Systems" as the negotiation partner for the respective örE in its collection area. Especially in the case of the latter, it is hoped that the representatives of the Dual Systems will come to an agreement quickly.
Central municipal organisations and negotiators basically recommend that a comprehensive provision be provided and that the Coordination Agreement be negotiated and concluded as a whole. An orientation aid for the Coordination Agreement is currently being drawn up and is planned for the end of April/beginning of May.
The principle of consensus and coordination principle is to be applied in the Coordination Agreement, as was the case to date. As an exception from this, in a framework requirement for the organisation of lightweight packaging (LVP) collection from private households, the örE can define the type of collection system as a pick-up or bring system or as a combination of both, and can define the type and size of the collection containers and the frequency and period of the container emptying. The framework requirement can be issued as an administrative decision or can be fixed as part of the Coordination Agreement.
Early consultation should take place for the LVP collection system design, so that the political decision-making process can be taken into consideration. Whether the collection is to take place in the yellow bin, yellow sacks or in recoverables banks or the recycling depot depends on many basic conditions and is often an emotional topic for citizens and politicians. It can therefore be useful to involve citizens through questionnaires on the future collection of LVP. At the same time, questions can be included on the attitude to the introduction of a recyclables bin, where in particular the economic feasibility of the introduction is also to be checked.
Arrangement of the joint PPK use is also part of the coordination and must be negotiated with the joint representative of the systems. Legal charges principles are to be applied to determine the appropriate remuneration. The costs component of the PPK sales packagings must be taken into account as a mass or volume component. After the decision for nationwide determination of the volume components by independent experts failed, an independent report for the respective collection area can be useful for the negotiations.
Furthermore, the incidental charges for PR work and collection bank site cleaning must also be included in the Coordination Agreement.
bifa offers support for all the aspects mentioned, which are required in a Coordination Agreement: From the analysis of the status quo to advice on the drafting and detailing of the agreement through to calculation of the joint use charges. Preparatory activities such as a survey of citizens on the system arrangements and providing advice and support for the political decision-making process are all standard services. Initial expert determinations of mass and volume components of the PPK sales packagings of different collection systems according to the largely agreed methodology have already been performed.
We will be pleased to advise you and perform appropriate analyses.