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

packaging has to be licensed by the DSD or an equivalent system. Also, retailers have
to issue a statement highlighting the level of completeness of licensing for the
packaging they have distributed. Exemptions can be approved by the public agency
responsible for the take-back-system. It is expected that this will lead to a
strengthening of the position of the DSD as in future, nearly all packaging waste is
expected to be covered by the dual system. For companies that choose selfmanagement
of packaging waste disposal, there is no free rider protection.
14.12 Lessons Learned
Despite the sometimes negative image presented by commentators, the DSD is
working quite well in terms of resource efficiency. The positive effects are mainly in
the enhanced recycling rates. Positive effects on waste prevention must be proven by
further in-depth analysis on this issue.
The system has been criticised, not without some justification, for being expensive.
Not all of this criticism has been well-informed, but it is almost certainly true to say
that in early days, contracts which were entered into by the DSD were not necessarily
competitively priced. Matters appear to have improved somewhat over time, but the
costs remain high. In one OECD document, Ingham notes: 277
261
Where recycling is economically viable, as it is with aluminium and steel
materials because of the high value of raw materials and the relatively low
costs of processing, and where low processing costs and efficient markets
make recycling feasible, government mandates may push industries to reduce
packaging waste without enormous economic disruptions. However, when
recycling faces higher technical and economic barriers, as it does with
plastics, government mandates may create enormous disruptions. The costs
of DSD rose as a consequence of including plastic packaging in the scheme.
Thus, despite the fact that the DSD system does take a large amount of
plastic material out of the waste stream, it is costly.
He concludes:
One weakness of the German system is that its goals are not based on a costbenefit
analysis and, as such the level is not chosen on the basis of an
economic rationale. (The dominant hierarchy of waste management gives
recycling a priority, and so to some extent is pursued for its own sake.) Whilst
Germany achieves high recovery rates, the DSD system shows that this is
expensive, and substantially exceeds the costs, including environmental costs,
of alternative waste disposal methods. The targets set by the German
government imposed have perhaps been too ambitious. High goals may be
reasonable for materials like aluminium and steel where recycling is technically
and economically practical, but such goals may not be practical for materials
like plastics.
277 Alan Ingham (2005) Improving Markets for Waste Plastics, in Improving Recycling Markets,
ENV/EPOC/WGWPR(2005)3/FINAL. Paris: OECD.
International Review of Waste Policy: Annexes