German Packaging Ordinance

The German Packaging Ordinance aims to reduce the impact of packaging waste on the environment. The ordinance governs the collection and recycling of packaging that is used by manufacturers and distributors. Not only does it concern companies that bottle and pack goods for instance, as well as the dual systems and industry solutions which they commission, but also mail order and Internet retail. The ordinance requires a variety of specialist reports to be produced, for example as evidence that industry solution packaging is recycled. Our experts at TÜV Rheinland can assist you with certifying recycling plants and auditing volume flow records or declarations of completeness.

It is important to note that the 5th amendment to the German Packaging Ordinance made it mandatory for some companies to submit a certified declaration of completeness (DoC) and connect to dual disposal systems.

• Declaration of completeness (DoC) preparation
• Volume flow record (VFR) preparation
• Plant testing

We will be happy to assist you with certifying recycling plants and auditing volume flow records or declarations of completeness. If you are required to provide evidence certified by an expert, please do not hesitate to contact us. We will create a customized offer for you based on the information you provide. Our experts will further coordinate your project with you. You can take advantage of our years of practical and industry experience, and the expertise of our specialists.

If prescribed volume limits are exceeded, distributors of sales packaging are required (under section 10 of the German Packaging Ordinance) to produce a declaration of completeness (DoC) and to submit this to the relevant chamber of commerce and industry (Industrie- und Handelskammer, IHK). This requirement does not apply if your company participates in an industry-specific self-disposal model. In addition, it does not apply to companies with less than:

• 80,000 kg of glass
• 50,000 kg of paper or cardboard
• 30,000 kg of other packaging e.g. plastics.

Before submission to the relevant IHK (by May 1 each year), the declaration of completion (DoC) is audited by a neutral body such as TÜV Rheinland, and requires certified proof of the volume of packaging sold to end users, as well as including details of the sales packaging by material type, self-disposed packaging and disposal methods. We would be happy to audit and sign your declaration of completeness before submission to the IHK.

With the German Packaging Ordinance, legislative authorities require various participants to provide volume flow records. These allow them to prove how much packaging they have sent out, taken back and recycled, as well as in what materials. Volume flow records are mandatory under the ordinance for companies who operate industry solutions (under section 6 para. 2) or manufacturers/distributors of hazardous contents (under section 8 parargaph 3). We would be happy to audit your volume flow records and issue the necessary certification.

Recycling plants (final recipient plants) for plastic packaging and packaging made from plastic or PPK composites require an expert certificate under the LAGA M37 guideline. This is the only way that these materials can be recognized as recycled for the purposes of volume flow records. TÜV Rheinland will audit plants for you on the basis of the German Packaging Ordinance and the LAGA M37 guideline. This audit calculates and certifies essential plant parameters such as capacity and availability.

This certification process has also proved successful even outside the scope of the German Packaging Ordinance, particularly in communications with the authorities and contractual partners throughout the value chain.

Why not combine your testing with industry-specific standards? This allows waste dealers and brokers who have their volume flows audited to be certified as disposal specialists under sections 56 and 57 of the German Waste Management Act or their quality and environmental management systems to be certified under ISO 9001 and ISO 14001. TÜV Rheinland combined certification allows you to establish a holistic management strategy and create the ideal conditions for your company’s development. You will also have a single point of contact. Speak to us to find out more about the possible the synergy effects.