Topic: Will many flexible plastic packagings and PS be considered non-recyclable in the future after the amendment of the minimum standard in Germany, as some press releases announce?


According to the consultation version of the German minimum standard, it is expected that categories 3c and 3b of Annex 1 to section 4.1 will be combined into a single category in the future. For this category, an individually verifiable proof will be required regarding the assessment criterion according to Number 4.1. Will the packaging types affected by this regrouping, namely PS rigid, PP-flex and small-format PE-flex packaging, be considered non-recyclable in future and how will the validity and assessments of CHI certificates be affected by this?


The validity of CHI certificates is not affected or restricted by the planned amendment to Annex 1 of the minimum standard. The two main reasons for this: 

  • Our certificates already consider limited availability of required infrastructure in the designation to individual states i.e., also for Germany, anyway (according to ISO 14021). We have therefore already been reflecting this planned change in the minimum standard for a long time through our criterion K0 and corresponding designation on the certificate.

  • The German minimum standard is an administrative regulation for the application of § 21 of the German Packaging Act (VerpackG) i.e., from a legal point of view it only regulates the classification of packaging in the internal relationship between the distributor and EPR systems within the framework of an eco-modulation. The CHI standard reflects the recyclability measured against the state of the art; the infrastructure criterion (recyclability at scale) is considered separately and additively in the respective national conditions. For the currently practically irrelevant case that a contradiction to the minimum standard will occur, only a note will appear in the certificate at the value for Germany that an individually verifiable proof is required when using the certificate in the context of the application according to § 21 VerpackG.

Topic: Conformity of the CHI method (CHI-RA) to the draft PPWR


According to the draft PPWR, an assignment of packaging of all material types to recyclability classes in mass-% (cf. Article 6 and Annex II, Table 2 PPWR (draft)) is required. To what extent does the CHI method conform to the requirements for the assessment method specified by the PPWR? And is the validity of current certificates affected?


In our standard for the assessment of recyclability, the determination and reporting of the result has been gradual from the beginning (since 2011) with metric scaling in mass-% based on transparent and methodologically well-founded accounting rules. This is also the minimum standard with which our standard (CHI-RA) complies.


Insofar as Article 6 and the associated annexes of the draft PPWR are already assessable, the CHI Standard is thus fully compliant with this. This may even be another exclusive characteristic of CHI-RA at present. For the time being, you can assign the result of our recyclability assessment to one of the 5 classes without adaptations.


However, the details of the future determination method of gradual recyclability according to PPWR have not yet been determined. The Commission has delegated the preparation of the necessary implementation guidelines to the European Standards Institute. Representatives of the CHI are actively involved in the drafting of the corresponding standards in the responsible committees of both DIN and CEN. According to the status of the work in the committees, we do not yet see any indications that anything has to change in our assessment methodology in order to be or remain "PPWR-compliant" in the future. In any case, we will ensure the latter.


Since our certificates are generally only valid for one year for several reasons, there is also no danger for our clients that expert findings that will have to be considered after the PPWR has been finalised - when, with whatever binding force and with whatever exact regulations will come into force - will not be taken into account. If there is a technically well-founded assessment regulation, and we assume that there will be, we are already optimally equipped with the CHI-RA.