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  • Dear Readers!

    The summer break has come to an end and people are gradually returning to work – as are the MPs in Berlin. Once again, environmental politicians are focusing on the subjects of waste management and recycling. The coalition agreement, signed by the Government in 2013, gives great importance to curbing global warming and using our planet’s natural resources efficiently and also expressly states that innovations that protect the environment, prevent climate change and preserve resources are also opportunities for economic growth. Industry specialists are well aware, however, that economic growth and more innovations are only possible if there are clear framework conditions in place that guarantee fair competition, if product responsibility is extended and if recycling targets are raised. The latter, in particular, can only be implemented if the necessary legal framework has been established so that joint kerbside collection schemes for packaging and other recyclables can be set up.

    Unfortunately, the latest draft bill for the new packaging law has failed to deliver what many had been hoping for. What we seem to have here is the eighth amendment to the Packaging Ordinance rather than a genuine recyclables law. Whilst there are a few positive approaches to remedying the current deficiencies, it does not deal with the question of whether waste made of similar materials to packaging should also be collected in recycling bins. The increased recycling targets are well below the volumes that could actually be recovered from household waste. According to the latest studies, an additional 7.8 million tonnes of raw materials could still be collected which in turn would reduce carbon emissions by a further 1.6 million tonnes. Moreover, the need for fair competition and a level playing field between the private and public sector companies has not been tackled in the draft bill either. And there is practically no mention of introducing effective ecodesign guidelines that would force manufacturers to think about how their products could be recycled when actually designing them. We must wait and see whether this draft bill actually becomes law. The private recycling sector believes that a number of improvements need to be made to the bill. Time is running out, however, with the general election coming up next year.

    REMONDIS demonstrates just what can be done with waste and how the very most can be made of these materials to curb climate change and protect the environment – such as at its Lippe Plant in Lünen. The efforts being made by the company here were officially recognised recently when KlimaExpo.NRW (a cross-departmental initiative of the state government of NRW to prevent climate change, conserve resources and achieve sustainable economic growth) added three of the Lippe Plant’s areas of expertise to its list of the twelve best projects in North Rhine-Westphalia. At this site, industrial and household waste is recycled and turned into primary products for industrial businesses, waste and residual materials are transformed into fuels and, last but by no means least, biomass is recycled or used to generate energy. These three areas of expertise alone reduce greenhouse gas emissions by around 416,000 tonnes every year – and are, therefore, getting as close as technically possible to achieving fully closed cycles. The Lippe Plant flagship project is becoming ever more effective. It is high time that this model becomes the norm so that future generations also have a planet worth living on.

    Yours

    Thomas Conzendorf

On the lookout for the right solution

This spring, four state environmental ministers from the Green Party proposed a compromise in an attempt to save the recyclables law which had effectively run to ground. By putting forward their suggestions, the states of North Rhine-Westphalia (NRW), Lower Saxony, Baden-Württemberg and Schleswig-Holstein were trying to redirect the debate away from the often ideologically driven question of who was responsible for what towards a supposedly more pro-business and more sustainable approach. Norbert Rethmann, honorary chairman of the supervisory board of the RETHMANN Group, read their comments with great interest and decided to put pen to paper. He responded to the initiative put forward by the four states by writing a letter to the environmental ministers, first and foremost to Johannes Remmel, Minister for Climate Protection, Environment, Agriculture, Nature Conservation and Consumer Protection for NRW. He not only expressed his own personal point of view here but also wrote about the concerns felt by the whole of the private sector.

In his letter to the environmental ministers, Norbert Rethmann calls on politicians to create the necessary framework conditions for the whole of the waste management and recycling sector

  • Dear Ministers

    Last week, I was invited by the GGSC law firm to attend a symposium to celebrate Mr Gaßner’s 60th birthday. Moreover, I read an article in EUWID (issue 14/2016) about your initiative to find a compromise for the recyclables law. Please allow me to make a few comments here.

    During the symposium in Berlin on 06 April 2016, Prof. Töpfer gave a talk that clearly illustrated the development of the Packaging Ordinance over the years and the path the country has taken on its way to becoming a recyclables economy. Being President of the BDE [Federal Association of the German Waste Management Industry] at the time the regulations for the Packaging Ordinance were originally drawn up, I was able to participate in many discussions and meetings.

    The outcome of this course of events can also be seen in the way our family-run business has developed. Back in 1977, I drew up a set of company guidelines for our then small workforce. One of our guiding principles at that time still remains true today: “At our company, recycling has priority over disposal.” I believe that this is the guiding principle for all efforts to recover recyclable materials and the first step towards creating a recycling economy.


    The challenges of recycling

    I have been following the discussion about the recyclables law with great interest but also with a degree of detachment. I believe the minimum recycling rates could be much more ambitious. The decision to recycle materials, also those collected from local households, has created some huge challenges for waste management companies. Working together with scientists and German industrial businesses, recycling processes and treatment facilities have been developed to make it possible for the majority of these substances to be returned to production cycles.

    Unfortunately, these first steps have been quickly forgotten. I would like to highlight the subject of glass here. Thanks to the change of attitude of glass manufacturers, brought about by the energy savings they could achieve (a third less energy), and the sorting processes developed by universities – here in particular the collection of glass according to colour – glass recycling has become the norm and not only here in Europe but across the whole of the world. There have been similar developments on the plastics market – especially for PET materials. Our family-run business will be opening a new treatment plant in Hamburg in the next few days which will be able to treat 20,000 tonnes a year.

    Alongside all this, a wide range of initiatives have been set in motion – in particular in industrial and commercial areas – to try and recover recyclable materials. Thanks to these efforts, our company alone is able to recover ca. 7 million tonnes of scrap metals and 2.5 million tonnes of paper every year.

    I would venture to say that, in around ten years’ time, these developments will have resulted in the waste management and recycling sectors being as important as the chemicals industry and automobile industry are today.

    There is already a big demand for recycling systems both here in Europe and beyond.

“I’d venture to say that, in around ten years’ time, (…) the waste management and recycling sectors will be as important as the chemicals industry and automobile industry are today.” 

Norbert Rethmann, Honorary Chairman of the Supervisory Board of the RETHMANN Group

  • Fair competition benefits local residents

    For the most part, if I have gauged the situation correctly, the discussions surrounding the recyclables law have been about who will be responsible for collecting these materials from the households in the future.

    This is actually a simple logistics task. In my opinion, this has nothing to do with essential public services. The real challenge here is finding ways to process the materials so that they can be returned to industrial businesses as primary raw materials.

    Being a competitive society within a social market economy, we are governed by competition and depend on these services being regularly put out to tender. In this respect, I have no issue whatsoever with both municipal companies and private sector firms competing with each other to take over these tasks.

    I do believe, however, that these tasks must always be put out to tender and that everyone must be subject to the same competitive conditions – especially as far as tax rules are concerned. There is no reason for municipal companies to be in a better position when it comes to taxes. Fair competition is needed in this sector so that local inhabitants can benefit.

    Private sector waste management firms are often accused of ‘cherry picking’, forcing the municipal waste management companies to step in and fill any gaps as their public sector duty. This is not true. For more than 25 years now, the collection of sales packaging has been put out to tender. These materials are being collected across the whole of the country as part of the so-called ‘dual system’ and it is the private sector firms that are operating in the rural areas of Germany.

    Of course, this can all take place under the responsibility of local authorities. Rules, though, must be drawn up to ensure that these services are put out to tender every five to eight years and these rules must then be adhered to.

    I have had the privilege of working as an entrepreneur in this sector for around 50 years now. I have always acted according to the motto “Accepting challenges, taking responsibility”. This has led to the development of an incredible number of innovations – developments which can, I believe, be put down solely to the commitment and efforts of the private sector.

    There is, of course, the possibility of the two sectors collaborating as public private partnerships to face and overcome future challenges together. Such partnerships allow local authorities to remain in control and give private sector firms the freedom to introduce innovative business solutions.

    There is no reason for municipal companies to be in a better position when it comes to taxes. Fair competition is needed in this sector so that local inhabitants can benefit.


    Adopting successful concepts

    Over the years, I have learned to orientate myself towards solutions that work well in practice. In this context, I would like to mention the ‘TierKBG’ [German animal by-product regulations]. I believe that the legal regulations for disposing of animal carcasses offer an excellent opportunity here as they could be transferred to set up similar fundamental principles for waste management laws. Our company has been operating in this sector for decades now, recycling and disposing of animal by-products, and is has become very clear that these regulations really guarantee that such materials are handled safely – protecting both consumers and the environment. I also believe that this is a very modern law that provides all those operating in the sector with many incentives to come up with entrepreneurial and innovative solutions.

    This has led to our company now having a 20% share of the global market for producing the anticoagulant heparin from mucosa and also to us producing 700,000 tonnes of protein for the animal feed industry, in particular, for the pet food industry. Moreover, we are involved in the production of blood plasma and the recycling of fish waste – with all the volumes here being large enough to be of interest to our customers.

    May I also touch on the investments that need to be made to set up modern processing facilities. Just one example here is the plant which we built in the Russian City of Kazan and which involved our company investing around 40 million euros. At least 25 million euros of this sum were spent on technical equipment from Germany and other European countries.

    These are all high quality machines (decanters, centrifuges etc). This development is, therefore, extremely important for Germany. We also saw this when we went to Singapore a few weeks ago to take part in the official opening of a plant for recovering metals from IBA from household waste incineration plants. The technology installed will enable the plant to handle 600,000 tonnes a year.


    The need for political concepts

    In my opinion, there will continue to be major developments in the recycling sector over the next few decades. For us, this means we will be able to provide 63,000 full-time jobs, with 2,000 apprentices and a large number of positions that will demand the very most – also in the area of science – from engineers, business people etc.

    Political concepts are needed here to set up future framework conditions. The issue here is not about making funds available to develop the umpteenth process to recover phosphate. What I feel is important is for politicians to create economic incentives – especially regarding the contamination of materials in the many different recycling processes.

    In some cases, manufacturers are taking the easy way out here: they produce cars and other consumer items. Once these have been used, they are returned and we are then faced with the challenge of recovering the metal, aluminium, copper and carbon from the composite materials (such as those from the automobile industry) so that they can be re-used. This is becoming more and more noticeable with components such as chips, printed circuit boards and control modules. They should be installed in the products so that they can be recovered easily at the end of the product’s useful life. If this happens, then these raw materials can also be recovered and re-used.

    I think that the discussions being held at the moment are too simple. People are currently talking about who may collect which materials. Instead they should be looking to solve this issue as a competitive society in line with a social market economy in order to direct more attention to all aspects of the subject: what happens to the raw materials after they have been used? How can they be recovered and returned? Just how effective are the checks being made to see how contaminated these materials are?

    We are doing our best to take responsibility here, making the most of our own laboratories, where more than 200 people are now employed, and of the options open to us. It would be nice, however, to see a much greater political reaction so such developments are taken more seriously. This is especially true for the question of the separate collection of organic waste – something that became mandatory by law in 2012. The German states have not succeeded in enforcing these regulations. Having experienced all this, who really expects a recyclables law to be strictly implemented?

    This letter has turned out to be very long indeed. I am, therefore, a little worried that you might not be able to find the time to read it and reflect on the points I have highlighted. Should you believe that a discussion about this subject would be useful for your decision-making process, then I would be more than happy to contribute to this discussion by passing on my experiences – or rather the experiences of our company – to you.

    Yours sincerely
    Norbert Rethmann

Johannes Remmel, Minister for Climate Protection, Environment, Agriculture, Nature Conservation and Consumer Protection for the state of NRW, responds to Norbert Rethmann’s letter

  • Dear Mr Rethmann

    Thank you very much for the letter you sent to Minister Höfken, Minister Untersteller, Minister Habeck and myself on 20.04.2016 in which you refer to the initiative put forward by a number of German states regarding the recyclables law and comment on a number of the fundamental issues relating to this topic. Your letter proved to have many similarities with the position of the German states that initiated the resolution passed by the Bundesrat on 29 January 2016 to create an efficient recyclables law that benefits the environment, consumers and local residents. I take great pleasure in replying to your letter on behalf of – and in consultation with – my colleagues.

    We agree with you that the decision to recycle materials, also those collected from local households, has created some huge challenges for waste management companies and that the current recycling targets could be considerably more ambitious. It is an indisputable fact that the real challenge here is finding ways to process the materials so that they can be returned to industrial businesses as primary raw materials. Your prediction that, in around ten years’ time, these developments will have resulted in the waste management and recycling sectors being as important as the chemicals industry and automobile industry are today cannot be contradicted either. This growth will provide the private waste management industry with more areas of activity and relevant legal regulations must be introduced here to strengthen this sector.

    • Johannes Remmel, Minister for Climate Protection, Environment, Agriculture, Nature Conservation and Consumer Protection for the state of North Rhine-Westphalia

    In our opinion, therefore, considerable efforts must also be made to achieve much more ambitious environmental targets, in particular by increasing recycling volumes and qualities by extending product responsibility. To reach such goals, we need a recyclables law that not only includes tough regulations regarding the recycling of municipal household waste but that also – at a later stage – implements product responsibility for commercial waste as well.

    For the most part, we agree with your statement that, being a competitive society in a social market economy, services must be put out to tender regularly and be governed by competition. Indeed, this was the reason why the proposal submitted by a number of states to make local authorities responsible for organising the collection, sorting and recycling of waste packaging and waste made of similar materials was not pursued. The Bundesrat has now ruled overwhelmingly in favour of a compromise in which local authorities are merely responsible for organising the collection of waste packaging and waste made of similar materials (including glass packaging via other containers) whilst the businesses responsible for the products must organise the subsequent sorting and recycling. This model ensures competition is not restricted.

    It should be highlighted here that local authorities should, as a general rule, put the collection of recyclables out to tender in line with public procurement laws. Notwithstanding the above, local authorities must be given the option to collect these materials themselves via in-house tenders. Local authorities are responsible for organising the services and have the right to decide how they should be offered to their local residents, e.g. via kerbside collection schemes or via recycling centres. A so-called standard cost payment scheme is being planned for the collection of light sales packaging and glass which should provide flat rates to cover all costs (including the previous ancillary costs). A transparent system will be used to fix these standard costs by looking at the results of earlier tenders put out for collecting these materials. This will make it possible to set up flat rates for the collection costs and will also ensure there is a cap on the costs so that they cannot grow disproportionately. Consequently, there will no longer be a need to negotiate the time-consuming and costly voting agreements, as is currently the case for paper, card and cardboard, which will also reduce the amount of red tape.

    The apprehension felt by the private waste management sector that local authorities may not put the collection of recyclables out to tender and so not open up the market to privately owned firms but (possibly increasingly) carry out these services (again) themselves and push out any competition is not without cause. However, it should be pointed out here, that these services are, for the most part, being put out to tender across the country. There is no reason why this should change especially as the private waste management sector can do a lot themselves to counteract the current trend towards renationalisation by submitting fair and competitive offers.

    On the other hand, it would be difficult to justify a public procurement law to a local authority with its own unincorporated business that forbids it taking part in the tender process for its own district or makes it necessary for them to change the status of their waste management business to that of a separate legal entity so it can participate in the tender. With this in mind, we would ask you to understand the point of view of local authorities who do not wish to have their public duties curtailed by being forced to put services out to tender, even if the volume of materials affected here
    is relatively small.

    Ultimately, it remains to be said that the main obstacle to a recyclables law being passed is the moot point of whether a relatively small number of local authorities should, in the future, be prevented from awarding contracts for waste collection services via in-house tenders. We do believe, however, that this problem is not insurmountable. On the other hand – and you may be in full agreement here – the success of a recyclables collection scheme depends very much on the volume and the quality of the materials collected by local inhabitants. It does not help here to simply raise recycling targets. So far, the Federal Ministry for the Environment has remained silent on this crucial issue because the dual systems are unable to influence households directly. Even manufacturers admit that local authorities play an essential role here providing a “face for local residents”. If local authorities have such a key role in this collection process – also because it is they that have the possibility to impose any necessary sanctions – then it stands to reason that they are also made responsible for organising the collection of the materials. This is one of the main reasons why we believe it is essential that they are given this responsibility.

    We very much hope that our arguments here have provided you with a greater insight into the position held by the states and have taken the liberty of assuming you are happy for this letter to be made public to a wider audience.

    Yours sincerely
    Johannes Remmel

    • of all raw materials used by industrial businesses are recycled raw materials


    • of recyclables could be re­covered from municipal waste


    • of recyclables could be recovered from German waste per person per year


    • currently work in the recycling sector – and this number continues to rise quickly

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