The packaging industry in Germany is calling for fundamental reforms to reduce bureaucracy and overregulation in order to be able to compete internationally. Reducing bureaucracy is crucial for maintaining prosperity and social cohesion.

• Companies are falling behind in international competition.
• Over 4,000 companies in the packaging value chain are affected.
• Bureaucratic hurdles lead to structural problems and long approval processes.
• Need for a national bureaucracy brake and standardization of reporting obligations.

Reliability and predictability for companies

Constantly changing requirements and unclear regulations are a burden on companies and prevent investment decisions. Reliable framework conditions are necessary to ensure planning security.

• Companies need clear and stable guidelines.
• Reacting too late and unclear deadlines lead to uncertainty.
• Investments in Germany are jeopardized by unclear regulations.

Involving expertise in legislation

The involvement of business experts in the legislative process is crucial in order to create practical and effective regulations. An early impact assessment is necessary.

• Technical expertise must be incorporated into legislation.
• Laws should be drafted in a practical and fact-based manner.
• A lack of expertise leads to counterproductive regulations.

Taking responsibility at European level

The reduction of bureaucracy must also be considered at European level in order to create uniform and practicable regulations. Germany should take responsibility in Brussels.

• Bureaucracy reduction must be coordinated at European level.
• Simple and practical regulations are required.
• Responsibility for regulations must also be taken at EU level.

Acceleration of approval procedures

Planning and approval procedures must be significantly accelerated so as not to hinder innovation and growth. Binding decisions are necessary at the end of planning processes.

• Approval procedures are taking longer and longer.
• Need for a pragmatic design of the procedural rules.
• Long processes slow down innovation and progress.

Unclear regulations in packaging law

The Single-Use Plastics Fund Act leads to uncertainties in the definition of affected packaging, which results in unnecessary burdens for companies. Clear and comprehensible laws are required.

• Unclear definitions lead to constant case-by-case decisions.
• Example: Salt sticks and yogurt cups are classified as “to go”.
• Legislation must be clear and comprehensible in order to avoid over-interpretation.

Avoid multiple reporting

Companies often have to report identical data several times to different bodies, which leads to unnecessary costs and time. Standardization of reporting is necessary.

• Duplicate reporting causes high costs.
• Example: LUCID database and DIVID platform require redundant messages.
• Digitization should be used to create interfaces.

Complexity of the new Packaging Ordinance

The new European Packaging Ordinance (PPWR) harbors risks due to its complexity and unclear regulations. Expert knowledge must be incorporated into the development of the regulations.

• PPWR leads to binding minimum quotas for reusable packaging.
• Lack of scientific basis for the regulations.
• Micromanagement leads to uncertainty and competitive disadvantages.

Promotion of fossil fuels hinders decarbonization

Current regulations put companies that invest in renewable energies at a disadvantage and slow down the necessary transformation of the economy. The climate targets for 2045 are at risk.

• Companies that use renewable energies lose special grid fees.
• Reform of grid fees could create incentives for fossil fuels.
• Example: Glass industry requires constant energy supply.

Distortion of competition through regulation

Regulations can lead to production moving away from Germany, which harms both the environment and the domestic economy. The same criteria must apply to domestic and foreign companies.

• Regulations lead to relocations to countries with lower standards.
• Example: Parchment production is moving to China and Turkey.
• Added value and jobs are lost.

Reporting obligations without clear guidelines

Binding reporting obligations without clear requirements for compliance lead to unnecessary hurdles for companies. Politicians must create realistic framework conditions.

• Companies are hindered by unclear reporting obligations.
• Example: EWKFondsG requires levies without audit guidelines.
• Necessity to create conditions for the fulfillment of requirements.