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Title: A qualitative and quantitative comparison of the German and Dutch government policies on packaging waste
Date: 26 Feb. 1998 (19980226)
Release date: Jan. 1999
Language: Dutch
Ordering number: 9901
Martijn Aarts, Gert-Jan Beernink, Chris Evenhuis, Jennifer Grant, Farrah Henriquez, Lindske van Hulst, Amber Kreleger, Ewout Krijger, Kevin Ooteman, Harold van den Os, Maaike Stomp, Matthias Zeeman, Levien van Zon

The full report (in Dutch) can be obtained from the Department for Information and External Relations ('Science Store') of the Free University in Amsterdam, De Boelelaan 1105, 1081 HV Amsterdam, The Netherlands. See the Dutch version of this page for more information on how to order from within The Netherlands.  





In 1994, the European Parliament introduced a Directive on Packaging and Packaging Waste, which was designed to help reduce the amount of packaging waste produced in the countries of the European Union. At the time of introduction, several countries including Germany and The Netherlands had already set up regulations and arrangements to this end. In The Netherlands a voluntary agreement, the Packaging Convenant, existed between the government and several parties involved in the packaging industry. It was superseded by the Packaging Convenant II, which implemented the EU Directive mentioned above. In Germany a law, The Packaging Ordinance, was in force obliging every company producing packaging material to take back the resulting packaging waste and recycle it.

The approaches taken to the problem of packaging waste in Germany and in The Netherlands seem to be quite different from each other. A superficial comparison between these two systems appears to favour the German approach because of better results. The purpose of this report therefore, is to provide a qualitative and quantitative comparison between the Dutch and the German system, in order to find out whether the German system does indeed yield the best results and to determine which aspects of either system are most favourable.


Background Packaging Convenant II

The Packaging Convenant II is an agreement on a voluntary basis between the packaging industry and the Dutch government. Its objective is to reach a higher recycling percentage for packaging waste than is required by the 1994 EU-directive on packaging and packaging waste. Companies that join the Convenant are relieved of the legal obligations set by the Dutch Regulations for Packaging and Packaging Waste, which implement the EU-directive in Dutch law. This agreement aims at a considerable decrease in administrative costs for both the government and the packaging industry.

The quantitative goals set by the Convenant involve setting the maximum amount of packaging waste to be dumped or incinerated to 940 kilotons in 2001. This is to be reached by a 10% prevention of packaging waste, adjusted for economic growth, and by a recycling percentage of 65%. It is not likely that 65% recycling will be reached however, because The Netherlands have no specific collection system for plastics.

The Packaging Convenant II will be evaluated in 1999. If the goals of the Convenant are not likely to be reached, stronger measures can be taken.

Collection and recycling

The packaging industry and the government are both partly responsible for the collection and recycling of packaging waste. The local governments organise the collection of household waste. The packaging industry has to organise and meet the expenses of recycling.


Prevention measures to be taken are stated in the prevention protocol of the Packaging Convenant II. The Convenant distinguishes between qualitative and quantitative waste prevention. One of the protocol directives states that manufacturers and distributors of packaging must annually determine the total environmental load of their packaging, with an emphasis on the amount of material used (quantitative), the possibility of recycling and the use of secondary (recycled) materials (both qualitative).


The amount of packaging material on the Dutch market (input) is registered by the Coopers & Lybrand company. The amount of packaging waste collected (output) and recycled is determined by the RIVM institute. The figures for recycling are obtained by RIVM from the recycling industry. Coopers & Lybrand and RIVM incorporate their results into a joint report, which is presented to the Packaging Commission. This commission monitors the progress being made in reaching the Convenant goals. If Coopers & Lybrand discover that a company does not keep to the agreements stated in the Convenant, this company can be excluded from the Convenant.


The Convenant is not yet completely accepted by the EU, as it is not a legally binding agreement. Political acceptance of the Convenant within the Netherlands however, is very high. This is also the case with the packaging industry, as it played a major role in setting up the Convenant. The Dutch environmental organisations and the largest green political party (Groen Links) have voiced some criticism against the Convenant. In their opinion the target reduction of packaging waste is not high enough from an environmental point of view. The consumer support for the Dutch system of household waste collection (mostly separate collection of materials) seems to be sufficient. However, there is still some criticism from the side of the consumer concerning the large amount of packaging used for some products.


Background of the German Dual System (DSD)

In 1991 the German government introduced a law which stated that manufacturers and distributors of packaging are responsible for collection and recycling of their packaging material after use. To make this task slightly easier, the packaging industry set up a non-profit organisation called Duales System Deutschland (DSD), which organises the collection of packaging waste. In order to do this, DSD in turn set up the Green Dot system, in which all manufacturers and distributors of packaging can participate. If a company decides to do so, it then pays DSD a license fee based on the amount of packaging it produces. In return, DSD will organise the collection and recycling of its packaging waste. A green dot printed on the product packing serves as proof to the consumer of participation in the Green Dot system.

Collection and Recycling

In both Germany and The Netherlands a bring-system is used for the collection of glass and paper / cardboard, in which the consumer deposits the waste materials at a local collection point. In both countries a curbside collection system is sometimes used for paper / cardboard instead.

The collection system for plastic, metal and composite packaging in Germany is very different from the one used in The Netherlands. In Germany the consumer deposits Green Dot packaging made of these materials into a yellow bag or container at home. This waste is then collected by DSD by means of a curbside collection system. The collected packaging waste is sorted by material and forwarded to appropriate companies for recycling. In The Netherlands packaging made of these materials simply ends up together with the normal household waste. This makes retrieval and recycling of the packaging waste later on difficult, as sorting of household waste is very a laborious and expensive procedure.

During the last few years, all collection and recycling quotas set by the German government have been met. In The Netherlands the quotas have only been met for paper / cardboard packaging. The percentages for recycling given by DSD are also higher than the percentages for recycling in the Netherlands.


The Green Dot system leaves the prevention of packaging waste to the participating companies. It is in their own interest to reduce packaging volume and weight and to make the packaging easier to recycle, as this will result in a lower fee to be paid for the Green Dot. The motivation for (qualitative and quantitative) prevention is in this case often purely financial in nature instead of being inspired by environmental consciousness.


In order to determine whether quotas are met, DSD has an extensive registration system for transport and sorting of collected waste (output). Input of packaging into the Green Dot system can be determined from production figures for each company that pays its license fees, as these fees are based on the amount of packaging produced by that company. The Green Dot licensing contract gives DSD the right to verify these figures.


The European Union approves of the fact that the German Government has enforced a legal obligation for waste retrieval and recycling for all companies. However, the EU fears that the high recycling quota for packaging waste (72%) might disrupt the internal European market, as the import of products into Germany is subject to the Packaging Ordinance regulations. The high quota also causes an increase in the supply of secondary materials on the European market, which could cause a significant drop in price for these materials.

The German companies do not like the fact that they have only very little influence on the German regulations regarding packaging and packaging waste. On the other hand the companies are relieved of the responsibility of having to organise collection and recycling themselves. This is taken care of for them by DSD, as long as they pay their fees. Several federal states and environmental organisations have called for stronger measures, especially concerning waste prevention. The German consumer seems to accept the Dual System, even though it causes a slight increase in product price.



Governmental Policy

In Germany the Government has set collection and recycling quotas to be met for the entire packaging industry, including the companies in the Green Dot system. In The Netherlands companies can join the Convenant and discuss measures with other companies, branch organisations and the government. The Dutch construction is somewhat more flexible than the German law, partly because laws are harder to change than agreements. Unfortunately the Convenant is also less binding than a law.

The Dutch Convenant is much cheaper than the German system. Efficiency is a factor of great importance in The Netherlands, while effectiveness is more important in Germany.

Companies and Prevention

Both the German Dual System and the Dutch Convenant have the same objectives, to ultimately reduce the amount of packaging waste produced and to make sure that any packaging waste still produced is easy to recycle. These goals are to be reached for a large part by quantitative and qualitative prevention of waste. Prevention in German companies can be financially beneficial, whereas in The Netherlands it mostly happens according to agreements.

Collection and Sorting

The Dual system in Germany provides a means to keep the packaging waste separated from the rest of the household waste. Because of this, German Green Dot packaging waste can be fairly easily sorted into separate waste streams for each type of material, which makes recycling and output monitoring relatively simple.

In The Netherlands, all packaging waste with the exception of glass and paper / cardboard is deposited with the normal household waste, which makes both sorting of materials and monitoring of the amount of packaging waste a rather difficult and costly process. This difference in collection methods is the main reason for the better results of collection and recycling in Germany, but it is also the cause for higher costs.


Both the Convenant and the Dual System require the partaking companies to report the amount and composition of the packaging they produce and market. However, the Green Dot system in Germany only covers households, public institutions and small shops. The rest, mostly large companies and industries, is taken care of by several smaller collection systems. In The Netherlands, for the monitoring of the Convenant all market sectors are taken into account, both for input- and output monitoring.

As the packaging waste in Germany is separated from the other types of waste and sorted according to material type, output monitoring can be done directly and accurately, simply by weighing the various waste streams. With the Dutch system such a simple measurement is not possible. All data must be obtained by taking waste samples and extrapolating results, which is far less accurate. In Germany the quality of the recycling process is also monitored. In The Netherlands this is not done, at least not officially.


Acceptance of and co-operation with the system might be slightly higher with the Convenant than with the Dual System, because The Convenant is based on agreements instead of on obligations. The participating companies have more influence on the Convenant than they have on the Packaging Ordinance.



For most Dutch companies in the packaging industry it is beneficial to join the Convenant, primarily for financial and administrative reasons. The main advantage of the Convenant is that it is well supported among most parties involved. The main disadvantage though, is the fact that it is not legally binding.

Under the Dual System in Germany, sorting and recycling of packaging waste is easier than within the Dutch system, therefore the results are much better. It is hard to compare the results of the Green Dot system with those of the Convenant, as the Green Dot collection system does not cover companies and industry. The main disadvantage of the Dual System is that it is very expensive.


Further study

There is still a lot of information missing from this report, most notably on the German system. For a complete overview of the German situation it would also be necessary to look at German collection systems other than the Green Dot system, especially the ones for industry and big companies. Moreover, other countries in Europe have adopted modified forms of the Green Dot system used in Germany. These usually have fewer disadvantages than the German system, although they might not be as effective. These systems could also be worth further study.