The calculation of the German take-back systems’ market shares for the fourth quarter of 2023 has caused some surprise.
The basis for the quarterly calculation by the Zentrale Stelle Verpackungsregister (ZSVR) are the interim reports of the German take-back systems. This interim report for the last quarter of this year has recently been submitted and raises questions from our point of view.
Significant drops in total quantity reported
Normally, it can be assumed that the forecasts for the packaging volumes placed on the market in the fourth quarter are higher than in the third quarter. This is mainly due to the Christmas season, when companies usually increase their sales volumes significantly, in line with consumer behaviour.
This year, however, the normal case has not occurred. The total market volume reported for Q4 is significantly below the expected value in the areas of LVP, glass and paper – in some cases even below the volume reports from Q3. We cannot understand this slump, especially since our customers’ forecasts for the months of October, November and December turned out as expected.
We expect an accurate verification of the data submitted
The reasons for this deviation are not apparent to us. We therefore expect a detailed review of this development by the ZSVR. The ZSVR has often commented on reports in the past, but has yet to comment on the current situation.
The responsible auditors (or experts) must also be called to account in order to verify the figures from the interim report.
It will also be interesting to see how the annual reports develop in the coming year. Will the predicted slump be confirmed or will it be shown that the interim reports were wrong?
How important is the “model of sustainability” in Europe really?
If the slump in volumes were to be confirmed, we would be confronted with a situation where we would see a clear discrepancy between the reported volumes from the previous year and the reported volumes from this year.
As PROs, we are committed to developing and constantly refining solutions for the collection and recycling of used packaging. However, we would have to interpret the development mentioned as an indication that some industry participants are apparently increasingly trying to evade their financing responsibility in parts. It is easy to talk about a sustainable approach to the environment, but the deeds that follow the words often fail to materialise.
The reduced participation volume also has a negative impact on the price level for the coming year. Higher participation fees create a further incentive for industry participants to look for ways to avoid their own obligations. As a consequence, there is ultimately a threat of failure of the competitive system approach and a possible remunicipalisation of the system – long called for by some political representatives. Fair competition needs rules of the game that also apply in critical times. This does not seem to be the case with the current design.