J M2ter Cy&s Waste Manag (1999) 1:17-24 , 0 Springer-Vet lag 1999

Erich Staudt Markus Schroll

The German packaging ordinance: the questionable effects of a fragmentary solid waste management approach

in: Journal of Material Cycles and Waste Management, Volume 1 (1999), Number 1 , pp.17-24 (ISSN 1438-4957) Springer-Verlag Tokyo

Received: February 4,1999 /Accepted: April 30,1999

Abstract Germany seems to be one of the leading nations in solid waste management, especially in the case of packaging waste; success stories about the ongoing increase in recycling strengthen this impression. However, enormous costs and questionable ecological benefits are the result of Germany’s packaging ordinance and the formation of the recycling organization Duales System Deutschland (DSD). This article shows that similar progress in the reduction and recycling of packaging could have been realized without the packaging ordinance and dual system, with lower costs. This regulatory impact analysis of the German packaging ordi- nance covers all the effects on the different life-cycle stages of packaging, from production to recycling or disposal. The conclusion is that a fragmentary solid waste management approach - one that is based, like the German packaging ordinance, more on ideology than on facts - leads to enor- mous costs and questionable ecological benefits. To improve this Situation, there is a need for an integrated solid waste management approach, based on evaluation of the eco- nomic, environmental, and social effects of different waste management options for the materials involved.

Key words Packaging . Packaging waste . Packaging regu- lation . Integrated solid waste management . Regulatory impact analysis

The current situation of solid waste management in Germany

Is Germany one of the leading nations in solid waste management? Success stories about the ongoing increase o f recycling in Germany strengthen this impression, but

often forgotten are the enormous costs and questionable ecological benefits connected with the attempt to imple- ment product responsibility and “close the loop” in this country.

What is the current situation in terms of solid waste man- agement policy in Germany? There is strict adherence to the waste hierarchy of “source reduction, reuse, recycling and disposal.”This indicates a lack of integrated solid waste management, because:

isolated product take-back and recycling obligations (e.g., for packaging, batteries, end-of-life vehicles) predominate;

material recycling is mandatory; energy recovery, incineration, and landfill are very limited.

Only a product-oriented, fragmentary approach to waste management exists, one that is based more on ideology than on facts. Furthermore, there is a lack of evaluation of the economic, ecological, and social effects of different waste management options for the materials concerned. Regulatory impact analyses are lacking as well. This situa- tion leads to enormous costs and questionable ecological benefits.

The pilot project for the predominant product take-back regulations - the German packaging ordinance - is a good example of the effects connected with such a fragmentary approach, or rather with the lack of integrated solid waste management.

The following statements are the updated results of several studies in the field of packaging, and especially of a regulatory impact analysis of the German packaging ordi- nance. These studies have been conducted since 1993 by the Institute for Applied Innovation Research (IAI) e.V., Bochum, Germany.’

1:. Staudt (a) . M. Schroll Contents and instruments of the packaging ordinance Institute for Applied Innovation Research (IAI), Bochum e.V., I3uscheyplatz 13, D-44801 Bochum, Germany Tel. +49 234 971170; Fax +49 234 9711720 e-mail: iai@ruhr-uni-bochum.de

The German Ordinance on the Prevention of Packaging Waste (packaging ordinance) was enacted in 1991.’ An

-.., amendment to the packaging ordinance was passed in 1998 and came into effect in August 1998. This amendment was necessary in order to fulfil the requirements of the Euro- pean Packaging and Packaging Waste Directive (94/62/EC), and of the German Waste Avoidance, Recycling, and Disposal Act (Kreislaufwirtschafts- und Abfallgesetz), as well as to eliminate regulatory gaps.

The overall target of the packaging ordinance is the pre- vention of packaging waste. As for packaging waste that does occur, its reuse and recycling has priority over disposal. This reflects Germany’s adherence to the waste hierarchy. In terms of the ordinance’s particular contents, we have to start with the general requirements for manufacturers and distributors of packaging. Packaging has to be manufac- tured and distributed in such a way that:

packaging volume and weight are limited to the minimum necessary to guarantee product quality and consumer acceptance;

reuse or recycling should be possible; environmental impacts of recycling or disposal should be as

With these requirements, the legislation emphasises the product responsibility of the affected firms. However, they are not legally binding; instead they are merely guidelines3

The prevention target of the packaging ordinance must be achieved rather indirectly by take-back and recycling obligations for the manufacturers and distributors of pack- aging. They are obliged to take back used packaging, free of charge, and to arrange for it to be reused or recycled. Alternatively, these obligations can be transferred to a third party. Through this command and control instrument, the legislator tries to get the packaging industry, the consumer goods manufacturers (e.g., fillers/bottlers), and the retail trade to take measures for the prevention of packaging waste.

The ordinance classifies packaging into three categories: transport, secondary, and sales packaging. This distinction is very important, because while the manufacturers and distributors of transport and secondary packaging are not exempted from the take-back obligations, an escape clause exists in the case of sales packaging. The take-back obliga- tions for sales packaging are ruled out if the affected com- panies join one or more nationwide collection systems - the so-called dual system -which guarantee a regular collection of used packaging at or near the household sources. Two demands are made.

On the one hand, the recycling quotas have to be met. In 1999, the recycling target for aluminium, plastics, and compositcs is 6O%, for paper/cardboard and tinplate it is 70%, and for glass it is 75%. Figure 1 illustrates the recy- cling quotas of the packaging ordinance.

On the other hand, the system has to harmonize with the local authorities’ existing systems for collection, sorting, and recycling.

It is important to mention here that material recycling is nznnrlatory, indicating that Germany does not have an inte-

low as possible.

80%

60%

40%

2 0 %

0%

75%

55 8

70% 70%

0- q*Qe

J from 1.1.1996

from 1.1.1999

Fig. 1. The recycling quotas of the packaging ordinance

grated solid waste management approach. Since the amend- ment of the packaging ordinance came into effect, limited permission for energy recovery exists for plastic packaging. At least 60% of the plastic recycling quota has to be met through mechanical recycling. Beyond this mechanical recycling quota, cleaner methods of recycling (mechanical recycling, feedstock recycling, or energy recovery) accord- ing to the German Waste Avoidance, Recycling, and Dis- posal Act (a 6 Abs. 1 Kreislaufwirtschafts- und Abfallgesetz) have priority.

To summarize, the prevention target is covered by the recycling quotas of the packaging ordinance. The attain- ment of the reuse and reduction target depends on the actual structures, and especially the incentive structures of dual systems and the like.4

The transformation of the packaging ordinance with the dual system

Ifi reaction to the emerging packaging ordinance, with its escape clause for sales packaging, 95 leading companies in industry and the retail trade founded an organization in 1990 entitled the The Green Dot - Dual System Germany - Society for Waste Prevention and Secondary Material mbH (this company has come to be known as DSD).’ The objective of DSD is to establish and maintain a system for the collection, sorting, and recycling of sales packaging. Moreover, the dual system is implemented nationwide. Figure 2 gives an overview of its working structures.

In accordance with the local authorities in rural districts and towns, the DSD has made contract agreements with waste management companies covering the collection and sorting of packaging waste.

In principle, there are two basic types of collection systems in the 537 contracted districts:‘

the kerbside system, in which the responsible waste management company collects lightweight packaging

-

__.

1 I ,

r weight fee

(plus rMtutory VAT) -

Fig. 2. Working structures of the dual system retail trade H packaging

manufacturers f i I ler/bo tt ler I I I I I I

1 1 consumer secondary raw material market

I I I

+ accept an ce/ waste management

plants guarantors (collection, sorting) recycling recycling companies

I L - - _ _ _ - - _ _ _ residue + -landfill f - - - - - -residue- 1 I

I

-incineration - contract agreements financial streams

(tinplate, aluminium, plastics, and composites) in yellow bins or bags from household sources;

the drop-off resp. bring collection systems, in which most commonly glass - sorted according to colour - and paperkardboard packaging is collected near the house- holds in containers, or at recycling stations.

Waste glass is transported via preparation facilities to glassworks; paperkardboard and lightweight packaging are transported to sorting plants. Paper is sorted according to the German standard quality list, whereas lightweight packaging is sorted (at 360 sorting facilities) into different material fractions as specified by DSD. After this, bales of the sorted fractions are transported to recycling plants, where recycling products or secondary raw materials are manufactured.

Here a major role is played by the so-called acceptance and recycling guarantors, working as recycling brokers. These companies contractually guarantee DSD a proper recycling of the sorted packaging. Depending on the mate- rial fraction described above, these companies are sub- sidiaries of the associated packaging manufacturers or firms, which were especially founded for the recycling and mar- keting of the sorted material.’

To finance the dual system, the fillers must pay a licence fee to use the registered trademark “Green Dot,” which signifies the right to participate in the dual system.’ The DSD’s licence fee takes into account the actual waste management costs of the different packaging materials, including financial subsidies for plastic recycling.’ As a result, the licence fee is composed of a material-specific weight fee and a volume- or area-specific item fee. Figure 3 shows the licence fee structure and two calculated examples.

Glass1

Tinplate.

Papadcardboardl

Aluminium=

Beverage cartons-

Other composites-

Natural materials1

Plastics-

0.15 DM/kg

0.40 DMAg

0.56 DM/kg

1.50 DMikg

1.69 DM/kg

2.10 DM/kg

2.95 DM/kg

0.20 DM/kg

+ additional

Item fee (pius abtutory YAT) depending on

or area volume I

I

~

c 50 ml 0 10-0 20 Pflitem I e 150cm* 0 10-0 20 Pfittem

0 30-0 40 Pfhtem 50 ml .ZOO ml 0 30-0 60 Pflltem I 150 -300 cm‘

> 200 ml - 3 iitres 0 70-0 90 P f m m I > 300 -1600 Fm’ 0 60 Pflitem

more than 3 litres 2o Pf/item 1 more than 1600 cm’ 0 9 0 Pf/item

I

I I

example I example

Plastic tub Cardboard header ~ 16.62 g x 2.95 DWkg . 12 70 g x 0.40 DM/kg 0 51 PI

Aluminium lid Plastic bag 0 51 g x 1 50 DMIkg 13 69 g x 2 95 DM/kg + 4 0 4 PI

4 55 Pi Total weight fee

200-400 ml) + 0 70 Pf Item lee (area 300-1 600 cm’) + 0 60 PI ..

2 4 j k c e n c e fee 5 15 PI - _ _ _ _ _ _ _ - _ ~

I I L - ____

Source Dualer Sysiam

Fig. 3. Licence fee structure

The structure of the licence fee is intended to have three functions:

it shall guarantee a fair material-specific allocation of the actual waste management costs (the producer-pays principle);

it shall inform the licencees about the financial conse- quences of material reduction and substitution;

it shall give the firms an incentive to avoid packaging waste, to reduce packaging material, and to use recyclable material.

Thus, the licence fee has the typical characteristics of an environmental charge."

At this point it is beneficial to ask: What are the impacts of the German packaging ordinance and the dual system on the different life-cycle stages of packaging? What are the benefits and costs?

t

sumers and the retail trade. Other important factors are the technological capabilities of the packaging machines and systems used, as well as pertinent regulations - for example, the regulations of the Food Law.

In summary, the packaging ordinance and the licence fee have little, if any, influence on packaging design. Con- trary statements that indicate a (mono)causal correlation between the packaging ordinance and the use and design of packaging material are scientifically untenable, and instead serve as a justification to perpetuate the existing system. They ignore the fact that companies reduced product pack- aging prior to the packaging ordinance for reasons of cost savings, and that this trend continues.

What has happened at the recycling stage of packaging waste, which was the real objective of the dual system? Here, too, the packaging ordinance and the dual system have resulted in questionable economic and ecological effects.

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Marginal effects on the production stage of packaging

Since implementation, DSD and its proponents have been publishing success stories about the resulting reduction in packaging material in Germany. Indeed, there has been a reduction, but not as a result of the packaging ordinance or the dual system. Figure 4 shows some examples of packag- ing reduction before the packaging ordinance came into effect."

Our studies show that strictly enforced efforts to save material costs over the last several decades have led to suc- cessful reductions in packaging material, regardless of the packaging ordinance. This tendency still continues. The analyses demonstrate that the ordinance has resulted in only marginal effects on the production stages of packag- ing. What are the reasons for this?

Firstly, the licence fee is, for the most part, passed on to the consumer. Therefore there is only an incentive to prevent or to reduce packaging material if it is not possible to add the licence fee costs to the product price.

Secondly, packaging design is mainly determined by product and market demands, by the expectations of con-

150-9 plastic yoghurt tub 1970 = 11 g

0.33-1 tinplate can 1985 = 5 g 1950 = 80 g 1992 = 33 g

4-1 soft rlnser plastic bottle 1970 = 300 g 1985 = 100 g

Fig. 4. Reduction of packaging material prior to the packaging ordinance

Questionable effects on the recycling and disposal stages of packaging

In response to the need to recycle packaging waste, regional monopolies evolved, caused by the mandatory harmoniza- tion between dual systems and the public authorities of towns and rural districts. Without the agreement of these authorities, no dual system could develop. The consequence was that especially the large waste management companies - dealing with the responsible authorities - secured the lion's share of the waste management contracts placed by DSD.The contractual period is 10 years, and a de facto com- pulsory participation exists for consumers.

Although the amendment of the packaging ordinance requires invitations to bid for waste management services, it remains to be seen whether these established monopolis- tic structures will be broken in the future. New contract agreements, currently being negotiated between the DSD and the waste management companies, are also for a dura- tion of 10 years. The E C Commission objects to this con- tractual period, fearing further stabilization of the existing monopolies. At present the contractors are looking for a compromise solution that meets the requirements of all parties.

The increasing burden placed on' the consumer through isolated collection systems for light-weight packaging, glass, paperkardboard, (normal) waste, compost, batteries, etc. is too great. The lack of information and motivation results in misguided behaviour, such as poor or incorrect separation of packaging, etc., resulting in a lower quality of the mate- rial collected. For example, in Frankfurt, the percentage of waste by weight in the dual system collection amounts to an average of 6O.l%, and can be up to 92.9% in large con- tainers.I2 In general, only 70% of the lightweight packaging collected by the dual system is recycled. The remaining 30% is made up of materials mistakenly put into the col- lection systems, plus sorting residues. These are collected and sorted at great expense, only to end up in landfills or incinerators.

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The joint collection of newspapers, magazines, and paperkardboard packaging results in an increase in low- quality waste paper. At the same time, prices have de- creased in the waste paper market owing to the increasing quantities collected and missing recycling and marketing possibilities. Another effect of the mandate for nation- wide collection has been a doubling of glass collection costs.

In the area of plastics, recycling has to be subsidised by DSD with large sums, e.g., DM 515 million (approx. US$284 million) in 1996 (collection and sorting not included). The reason for this is that the secondary raw materials and prod- ucts are not competitive. For example, DSD's total costs for secondary plastics granulate are DM 3000-3500 (approx. US$1650-1900) per tonne. This is more than twice the price of primary plastics.

Industrial standards are another obstacle to the sales and use of recycled products made of post-consumer plastic packaging. According to the results of a scientific study, three-quarters of the sample standards examined rule out the use of secondary plastics produced from post-consumer pa~kaging. '~ In spite of these marketing problems, the sub- sidies have led to a build-up of overcapacity at plastics recycling plants. Faced with this overcapacity, in addition to contract agreements between the responsible acceptance and recycling guarantor and the recycling companies, it is questionable whether the possibility of energy recovery can be established in practice.

At the disposal stage, incineration and landfill costs have increased. Faced with lower disposal quantities, the opera- tors of landfill and incineration facilities complain about poor capacity utilization. Together with high fixed costs and increasing requirements from environmental regulations regarding the operation of such disposal facilities, the result is an increase in costs per tonne.

Considering the developments described above, one has to ask whether the packaging ordinance has had only neg- ative effects at the recycling and disposal stages. With the

Quantity recycled [1,000 metric tons]

Glass

Paper, Cardboard

Tinplate 69 31 2

40

Plastics 567

Composites 8 6 420

Recycling quotas echleved by the Dual System In 1997 [XI' Packaging Ordinance (1991) recycling targets [./-I'

'based on sales packaging consumption sovrce Dudes S " " 7 (eo) (19981

Fig. 5. Recycling targets of the packaging ordinance fulfilled

quantities of packaging collected, sorted, and recycled by the responsible waste management companies, a positive effect seems to exist. As shown in Fig. 5, the recycling targets of the packaging ordinance have been reached. In total, the DSD collected over 5.6 million tonnes of packaging in 1997.

However, one has to remember that the collection and recycling systems already in existence would have been extended, or at least maintained, even without the packag- ing ordinance and the dual system. So what would have hap- pened without the dual system?

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What would have happened without the dual system?

Even before implementation of the dual system, paper/ cardboard, glass, and tinplate were collected almost nation- wide, and costs were mostly met. Additionally, some towns and rural districts collected other recyclable materials. In 1990, a total of over 2.5 million tonnes of waste were col- lected separately and recycled (Fig. 6).14 Faced with the poor competitiveness of secondary raw materials or recycled products made from plastic packaging or composites, it is uncertain whether collection systems for this packag- ing waste could have been established at the household level without the packaging ordinance, but it is certain that the collection systems for glass and paperkardboard would have been extended even without the packaging ordinance.

According to our calculations regarding the develop- ment of the quantities of glass and paperkardboard col- lected, over 3.5 million tonnes of packaging waste would have been collected in 1997 even without the dual system (Fig. 6). Therefore, a maximum of 2 million tonnes - that is just over one-third of the total amount collected in 1997 - can be exclusively attributed to the dual system. How much do these small (and to some extent, questionable) ecologi- cal benefits cost?

Quantity collected [l.OOO melric ions]

3.587

2,537

/---------. 5.000 I ..._----

further quantity collected by DSD

-. - - ----- - -- -

4.000

,/

3 000

1990 1993 1 9 9 4 1 9 9 5 1996 1 9 9 7

Fig. 6. Development of the quantities of packaging collected

Annual costs of the dual system

In total, participation in the dual system costs companies and consumers more than DM 9 billion (approx. US$5 billion) per year (Fig. 7). This means that each of the extra 2 million tonnes collected as a result of the dual system burdens the affected companies and consumers with an average payment of DM 4400 (approx. US$2425). In con- trast, incineration (including collection) costs an average of DM 650 (approx. US$360) per tonne.

To finance the dual system, licence fees of more than DM 4 billion (approx. US$2.2 billion) were paid in 1997 -mainly by consumers via product prices.The reasons for these enor- mous costs are:

the mandate for nationwide collection of all packaging materials at the household level;

the setting of high recycling quotas; the mandate for material recycling.

To fulfil these planned economy regulations of the pack- aging ordinance, the dual system had to establish collection systems in the most remote areas of Germany, making it possible to collect even very small amounts of packaging. The consequences of collecting every last milk carton in every tiny village is enormous expenditure on logistics and sorting, and these DM 4 billion are not the total of all costs incurred.

For the consumer, additional costs appear because of the presorting, cleaning, storage, and transport of the used pack- aging. On the one hand, the cost amount depends on indi- viduals' behaviour (for example, the water and energy consumption for cleaning depends on the cleaning method and intensity). On the other hand, it depends on the struc- ture of the collection system (for example, gasoline con- sumption for the drive to the recycling containers depends on the distance). At a conservative estimate, such costs

licencees: transactionladministration costs > DM 2 billion

consumem cleantng, storage, ‘sorting, transport s DB 9 bllllon

licencees/consumers: ~ licence fees

total > DM 9 billion

Fig. 7. Annual costs of the dual system

amount to more than DM 3 billion (approx. US$1.65 billion) per year for all German households.

With participation in the dual system, the consumer has the theoretical option to decrease costs for the remaining waste through a reduction in bin volume. In practice, however, there are limits to this possibility, e.g., in blocks of flats where a reduction in waste quantities depends on the behaviour of all the inhabitants, or in towns and rural dis- tricts where a minimum bin volume per person is manda- tory. We assume that reductions in bin volumes seldom occur in practice.

At the same time, waste disposal costs have increased since 1990, due to a combination of lower disposal quanti- ties with constant fixed costs and higher environmental requirements at the disposal facilities. Consequently, the waste disposal costs that may be saved by reduced bin volume are partly compensated through an increase in the waste disposal fees. In cases where bin volumes cannot be reduced, waste disposal fees for the consumer increase despite overall lower quantities of waste for disposal.

Last but not least, there are the transactional and admin- istrative costs for the firms involved. Experts interviewed estimate that the administrative tasks - such as contract implementations and settlements with the DSD - cost at least DM 2 billion (approx. US$1.1 billion) per year. Con- sidering the enormous costs and the controversial ecologi- cal effects, one has to critically examine to what degree the recycling of used packaging may be useful.

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Recycling and incineration

From an economic point of view, a comparison between the marginal costs of recycling and incineration provides a first approximation for the degree of recycling that may be useful (Fig. 8). The y-coordinate indicates the marginal costs per tonne, and the x-coordinate shows the recycling quota. As a rule, the recycling costs increase with rising recycling quotas. The reason is that the fulfilment of high quotas necessitates the collection of even very small-sized packag- ing nationwide. In the example of the dual system, this means overall waste management costs up to approx. DM 3000 (approx. US$1650) per tonne, depending on the mate- rial. In contrast, incineration costs \an average of DM 650 (approx. US$360) per tonne (including DM 3OO/US$165 per tonne for collection).

In economic terms, a useful recycling quota is situated at the intersection of the x and y axes. In this example, a recy- cling quota of 65% seems to be useful. For the remaining packaging waste, especially for very small-sized packaging or for composites that are difficult to separate, incineration seems to be a more economic alternative.

However, this is not a call for a new, lower recycling quota. The graph is a very general illustration, and disre- gards the various material-specific aspects of recycling costs. Rather, it demonstrates the relations in principle, and makes it clear that high recycling quotas and their overfulfilment are economically inefficient.

~

marglnai costs per metric ton

DM 3,000 -

DM 2,000 -

DM 1,000 - incineration

(DM 650)

recvclina . - 50% ‘ 100% quota‘

DSD-quota 1997 (86 %)

I based on sales packaging consumplion

Fig. 8. Comparison between marginal costs of recycling and incineration

To answer the question of whether recycling is ecologi- cally more effective than incineration, one can go back to the results of life-cycle analysis. For example, German life- cycle assessment^'^ on the recycling of used plastic sales packaging conclude that, even from an ecological point of view, incineration represents a useful alternative. This is especially true if incinerating plants also work as thermal power stations with high. efficiency, integrated into power and heat supply networks.

The final conclusion is rather disillusioning. The packag- ing ordinance has led to a system that guarantees fulfilment of the recycling quotas, but it is ecologically absurd and eco- nomically unreasonable - the same ecological benefits could have been reached at half the expense.

Conclusions for integrated solid waste management

Strict adherence to the waste hierarchy of “source reduction, reuse, recycling, and disposal’’ does not allow optimization of Germany’s waste management systems. Recycling mandates should be based on facts and not on ideology.

Isolated, product-oriented waste management appro- aches are often inefficient solutions. The contents of the wastes determine their suitability for landfill, incineration, or recycling. Therefore, an integrated solid waste manage- ment approach - one that recognizes all waste management options, and is aimed not only at products but also at materials - is most useful. Figure 9 illustrates a model for integrated waste management> which stresses the inter- relationships of the parts of %he system.16

Waste management decisions should not be made only for the disposal stage of materials. They can impact on a number of stages in the life-cycle of a product or substance. Therefore, integrated solid waste management requires material-oriented, life-cycle approaches based on an evalu- ation of the environmental, economic, and social effects

COLLECTION

a waste-to-energy

Source While. P R , Frsnke. M , Hindle. P (1995)

Fig. 9. The elements of integrated waste management

of different waste management options for the materials concerned.

Last but not least, the prevailing conditions at a local or regional level have to be taken into account. Every com- munity or region has its own unique profile regarding solid waste. Therefore, one waste management practice that is best for all situations simply does not exist. Each commu- nity or region must create its own way of dealing with its waste.

If one wants to find economically efficient and ecologi- cally effective solutions, one must establish integrated solid waste management systems. However, first one must answer the following questions.

What alternatives exist for the materials involved? What are their costs and benefits?

What alternative solutions are realistic in each particular community or region, according to the prevailing condi- tions? Do treatment and disposal, plants already exist? What are the specific financial and legal situations?

Finally, how do the economic and ecological effects of the various alternatives compare with one another? These have to be judged and weighed;one against the other.

I

References and notes

Staudt E, Kunhenn H, Schroll M, Interthal J (1997) Die Verpack- ungsverordnung. Auswirkungen eines umweltpolitischen GroSexperimentes. Schriftenreihe Innovation: Forschung und Management, Band 11. Institut fur angewandte Innovations- forschung (IAI), Bochum The packaging ordinance came into effect for transport packaging ‘

in December 1991, for secondary packaging in April 1992, and for sales packaging in January 1993 Flanderka F (1993) Verpackungsverordnung. In: Bruck w, Flanderka F (eds) Verpackungspraxis (VP-Recht). Loseblatt- Ausgabe, Huthig, Heidelberg, p 5ff Spies R (1994) Der “Grune Punkt” als Bkonomisches Instrument in der Abfallwirtschaftspolitik. Z Angew Umweltforsch 3:309-321

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24 ~

5. In 1997 more than 600 companies had a share in DSD. Owing to the multitude of shareholders, the DSD was transformed into a stock company on January 1, 1997, For more details about the history of the origins of DSIY, see, e.g., Philipp A (1993) Duales System, Rucknahmepflicht und Pfandregelung. Eine vergleichende Untersuchung unter besonderer Berucksichtigung des Einzelhan- dels. Mainz, p 36 ff

6. Three hundred and fifty-seven private companies, 104 municipal waste management companies, and 76 private-public partnerships were the contractual partners of DSD in 1998. See Bruck W (1998) Abfallwirtschaft unter Druck. Die Ausschreibung aller Vertrage des Dualen Systems wird kommen. Frankfurter Allgemeine Zeitung dated August 31,1998,201:B7

7. For detailed information on the acceptance and recycling guarantors, see the DSD internet homepage: http://www.gruener- punkt.de

8. Generally, the consumer goods manufacturer applies for the “Green Dot.” In the case of imported goods, either the German importer or the European exporter is the licencee. Companies located outside thqEuropean Community cannot apply. In the case of service packaging, the packaging manufacturer is responsible for the registration. By the beginning of 1998, the number of licencees had increased to 17234. See Duales System Deutschland AG (DSD) (ed) (1998) Geschiftsbericht 1997, Koln, p 20

9. Staudt E, Hafkesbrink J, Rebhan A, Siebecke D (1993) Wie man das Verursachungsprinzip operationalisiert: Die Novellierung der Gebuhrenordnung der Duales System Deutschland GmbH vom October 1,1993. In: Staudt E (ed) Berichte aus der angewandten Innovationsforschung No. 121, Bochum

10. In the strict financial economic sense, fees for environmental ser- vices charged by a company do not represent environmental charges. The licence fee, however, is indistinguishable - both in its impacts and from the licencee’s point of view - from national envi- ronmental charges. Thus, the licence fee can be assigned as an eco- nomic instrument “environmental charge.” Cf. Umweltbundesamt (UBA) (ed) (1994) Umweltabgaben in der Praxis. Sachstand und Perspektiven. Texte 27/94. Berlin, pp 8,26 ff. Concerning the defin- ition problems of environmental charges, see, e.g., Feess E (1995)

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Umweltokonomie und Umweltpolitik. Vahlen. Munchen, p 69ff, and the corresponding literature

11. For details concerning plastic packaging, see Industrieverband Verpackung und Folien aus Kunststoff (IK), Verband kunststoff- erzeugende Industrie (VKE) (eds) Verpacken in Kunststoff. Bad Homburg v. d. H., FrankfurVMain. For details concerning tinplate, see Informations-Zentrum Weissblech (IZW) e. V. (ed) (1994) Weissblech. Daten und Fakten. Dusseldorf. For details concerning glass, see Uhe H (1994) Moderne Leichtglas-Technologien und ihre Vorteile fur die Marktbeteiligten. In: Verpackungs-Rundschau (ed) 7. Internationaler Verpackungskongress. Verpacken - Praxis und Umwelt. Dokumentation, Keppler, Heusenstamm

12. Muller R (1998) “Gelbe Tonne” verkommt zum Restmullbehalter, VDI-Nachrichten dated June 26,1998

13. A sample of 171 representative DIN, EN, KO, and VDE standards was analysed. For details, see Deutsche Gesellschaft fur Kunst- stoffrecycling mbH (DKR), Fraunhofer-Institut fur Systemtechnik und Innovationsforschung (FhG-ISI) (eds) (1998) Perspektiven der werkstofflichen Verwertung von Sekundarkunststoffen der DKR. Behinderungen der Verwertung durch Normung. Karlsruhe

14. Statistisches Bundesamt (ed) (1994) Umweltschutz. Fachserie 19, Reihe 1.1 dffentliche Abfallbeseitigung 1990. Metzler Poeschel, Wiesbaden, p 32ff

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