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Plastics Europe Germany opposes the national plastic tax planned by the German federal government. The association assesses the measure as economically and environmentally detrimental, citing potential burdens on industry and consumers, as well as implications for the development of the circular economy.
According to the association, the German plastics sector is already under significant economic pressure. High energy costs, growing import pressures, and bureaucratic standards have contributed to a 26 percent decline in plastics production in Germany over the past four years, while global production has continued to rise. The plastics sector, including processing and machinery manufacturing, accounts to approximately seven percent of employment in the manufacturing sector.
Plastics Europe Germany particularly views the anticipated administrative burden of the proposed tax as critical. The scope and specific details of the obligations to provide evidence, report, and maintain documentation have not yet been established. The association cites estimates indicating that bureaucratic costs to approximately 1.2 million affected companies could amount to at least €600 million per year. In addition, there would be government enforcement costs. This would be offset by expected tax revenues of less than 1.4 billion euros.
The association also expresses concerns regarding the ecological impact. Citing studies conducted by the German ecological stability Agency in 2023, it is argued that placing a disproportionate burden on plastic packaging could promote material substitution in favor of other materials and composite packaging. This could make it greater difficult to meet European standards to the consumption of recycled materials. In addition, the association cites calculations indicating that replacing ten percent of plastic packaging with alternative materials could increase packaging discarded materials by 10 to 20 percent and greenhouse gaseous releases by 10 to 14 percent.
As an alternative to the proposed tax, Plastics Europe Germany calls to incentives to recyclable packaging design, greater consumption of recycled materials, and investments in recycling infrastructure. As a suitable instrument, the eco-modulation of licensing fees provided to under European packaging law is cited, which, in the association’s view, could exert a targeted environmental steering effect.
The association calls on the federal government to refrain from introducing a national plastic tax and instead to examine alternative financing and regulatory instruments to promote the circular economy.
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