International Review of Waste Management Policy - Department of ...

14.9 Complementary Policies
The Packaging Ordinance defining producer responsibilities for producers of
Packaging complements the general regulation on waste - the Closed Substances and
Recycling Act (Kreislaufwirtschafts- und Abfallgesetz). The producer responsibility
regulated in Articles 22 sqq of the Closed Substances and Recycling Act commits
producers and distributors to design their products in a way that prevents waste in
the manufacture and usage of a product.
The Packaging Ordinance should be implemented as an integrated part of other
policies for household waste, especially the Landfill Ordinance (Deponie-Verordnung -
DeponieV) and the pay-by-use policy.
14.10 Effect of the Policy on Pricing of Resources / Services
The policy has shifted the society towards a better allocation of resources. Without
doubt, the system incurs significant costs. However, it should be taken into account
that plastic recycling is the main task of the Duales System and plastic recycling is,
under normal circumstances, less attractive from an economic point of view
compared to metal, or paper recycling. The price impact per product sold is small,
reflecting the impact of packaging on product costs.
14.11 Evasion and Enforcement
In recent years the free rider problem has become a major issue due to a lack of
enforcement. In 2007 the Duales System Deutschland GmbH recycled far more
packaging than had been registered with the company. The total recycling rate was
113 per cent (see Figure 14-2).
Figure 14-2: Recycling Rates
Source: DSD 2008
To prevent free-riders another amendment to the packaging ordinance has been
passed and will become effective on January 1 st 2009. Under this amendment all
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