PETnology Europe 2024_summiteer

The Definition of PCR - “Favouring inefficient production methods?“

An interview by Barbara and Otto Appel with Reinhard Schneider, CEO of Werner & Mertz GmbH.


Sustainability is a key issue at Werner & Mertz, and their head office is the ideal place in which to discuss it. Schneider quickly turns our conversation to a topic which is weighing heavily on his mind: the definition of recyclate. In the run-up to the introduction of the new German Packaging Law (Verpackungsgesetz) on 1 January 2019, the question is specifically which types of recyclate should be permitted to be used in packaging. Even more importantly, for Schneider, which types of recyclate should be permitted to be labelled as such — and therefore taken into account when calculating licence fees. At first, this may seem to be a very German issue. After all, it is the wording of the new German Packaging Law which has provoked the debate. However, the topic itself is relevant far beyond Germany. For Schneider, the central issue is the difference between post-consumer recyclate (PCR) and post-industrial recyclate. It isn’t the use of post-industrial material to produce packaging that he objects to: “I’m not questioning the act of recycling industrial waste. This is an age-old practice and there’s absolutely nothing wrong with it at all.” Instead, he is concerned by the way this waste is declared.


Schneider answers these questions with an unequivocal “no”. And this is where his fight begins. In the ISO standard 14021, post-industrial material is also defined as recyclate. According to the ISO standard, this material can be included in the total proportion of recyclate declared per bottle. 

Schneider is not the only one with his eye on the consumer. In its information video on the new German Packaging Law, which is available on YouTube, the Zentrale Stelle Verpackungsregister (Central Packaging Registry) describes how the new legislation will help the environment. The film shows a family shopping, cooking, cleaning and disposing of their rubbish. The rubbish is collected and separated so that all the recyclable materials can be sent for recycling and reuse. What materials do consumers have in mind when they stand in the supermarket and choose a bottle of washing-up liquid which — and they check this carefully — has been deemed to contain, let’s say, 50 percent recyclate? Only the materials which experts refer to as post-consumer recyclate, of course. This makes consumers feel good about themselves, since they have helped to ensure that packaging they have used and correctly disposed of is subsequently recycled and used to produce new packaging; that the plastic they have used will not end up in the environment or the sea, in landfill or incinerators. The higher the proportion of recyclate, the better. This is how the reusable materials cycle is perceived by consumers. It’s a logical, reassuring image.

Schneider is warning against allowing post-industrial material to be counted towards the amount of recyclate in a product, such as the figure of 50 percent in the example above — he sees this as a way of misleading consumers. The makers of information videos, at least, seem to feel the same way. They make no mention of post-industrial material at all.

Section 21 of the new Packaging Law states that packaging will be given preferential treatment based not only on its recyclability, but also on the proportion of recyclate it contains. “Preferential treatment” here means lower licence fees. In light of this, Schneider is not surprised by efforts to ensure that post-industrial material can be included in the proportion of recyclate. He knows from experience that producing high-quality packaging with a high proportion of (post-consumer) recyclate takes a long time and involves a learning curve. He believes that including post-industrial material in the proportion of recyclate would not only deceive consumers, but would also enable manufacturers to cut corners and take shortcuts. It goes without saying that he considers this to be unfair: “I feel that the whole situation is favouring an inefficient production process. Offering these incentives would even reward manufacturers for their inefficiency.” In an extreme-case scenario, this would mean that post-industrial recyclate could crowd out or even replace post-consumer recyclate. “Why? Because companies would be able to advertise a high proportion of recyclate purely by using waste created during production processes,” says Schneider — the ISO standard would allow both post-consumer and post-industrial material to be counted towards the proportion of recyclate declared for a piece of packaging. Schneider believes there is still a chance that the new Packaging Law will define clear rules which will prove benefi cial for post-consumer material and, in turn, for consumers and the environment.

Schneider is highly regarded and well connected, and he makes suggestions and voices his concerns whenever he can. In September 2018, he was invited to the G7 Environment Ministers’ Meeting in Halifax to present Frosch as an example of best practice in the field of resource efficiency. During the event, he explained his view on post-consumer and post-industrial material to the German Federal Minister for the Environment. He is aware that the issue is currently being analysed by an Expert Committee of the newly created Central Packaging Registry. This group of experts is in charge of the handling, observance and monitoring of the environmental objectives. He also knows that it will be the German government which will tip the scales. Schneider had his say in Brussels, too, when he was invited to attend a CEO breakfast during a stakeholder conference in the run-up to the publication of the European Commission’s Strategy on Plastics. As the owner of a medium-sized company, Schneider is often something of an exception in such settings, he says. In Brussels, it became apparent that the large companies were mostly looking to play for time, citing a need for general, international standards, for a liberal approach beginning by holding discussions with international stakeholders at the grassroots level and trying to come to an agreement there. “By the way, we’ve already got started,” interjects Schneider. He then confirms that the technology is advanced enough to produce sustainable packaging containing a high proportion of recyclate which will also sell well. His call for simple raw material — PET which is either colourless or only lightly coloured, and ideally free of barrier materials — has fallen on deaf ears in the detergents and cleaning agents industry. 

However, Schneider has more arguments to support his views. In 2012, he founded the multiple award-winning Recyclate Initiative. The idea behind the scheme was to take PET and PE waste from the yellow bags used to collect household packaging waste in Germany, process this into high-quality material and utilise it to produce packaging in a closed material and production cycle. This marked the first time that waste from the yellow bag would be used to manufacture packaging. “Today, we are the world’s leading manufacturer of packaging made from 100 percent recyclate, and we will soon have produced 200 million bottles.” A great deal of time and money went into this success. However, it created an important quality which is now just as intrinsic to the Frosch brand as the biotope is to Werner & Mertz’s head office: credibility. Credibility created through a holistic approach. Frosch emphasises that not only are its products environmentally friendly and sustainable, but the entire brand and all its formulations are free from microplastics. This meant that it was only logical for the company to manufacture its packaging too as sustainably as possible.

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