Plastics

Plastics are ubiquitous and are used across all economic sectors, in the majority of production processes and an innumerable variety of products, such as vehicles, buildings, infrastructure for electricity, water and wastewater, electronic devices and modern medicine. There is an urgent need to transition to a circular economy  in the plastics sector due to its low circularity and the increasing global consumption of plastics. In 2021, plastic production in Germany amounted to approximately 21.1 million tonnes, of which only 1.65 million tonnes were from recycled content. The vast majority of plastics placed on the market are petroleum-based. Biobased plastics account for around one percent of the German market.

Of the total annual plastic waste generated in Germany, which amounts to 5.7 million tonnes, 64 percent is still incinerated, while only 35 percent is recycled. In the case of post-consumer waste, 33 percent undergoes material recovery. This primarily involves mechanical recycling processes, while chemical recycling processes currently account for a marginal share of 26,000 tonnes. Given that chemical recycling is more energy-intensive than mechanical recycling, it should only be used as a complementary process where mechanical recycling is not feasible or, for example, where particularly high standards are required for the end product (such as single-use nappies and food packaging). 

Plastics are primarily consumed, in descending order, in the construction, packaging, automotive and electronics sectors. Without a reduction in plastic production and a fundamental shift towards circularity, approximately 56 gigatonnes of CO₂ would be emitted globally by 2050 from plastic production and incineration alone. This is equivalent to 10–13 percent of the remaining carbon budget needed to stay within the 1.5°C target. The chemical industry thus faces the major challenge of transitioning to a fossil-free raw material base. Three approaches are being discussed: the most significant is the use of plastic waste as recycled material. Additionally, biomass can be used, though it is only available to a limited extent and must come from sustainable sources. Another option, provided it contributes to climate change mitigation, is CO₂ from point sources and the atmosphere (carbon capture and utilisation – CCU, see Section ‎1.4). Increasing plastic circularity can reduce the demand for primary raw materials. However, the potential of recycling processes remains limited by current technological capabilities, depending on the application. This presents challenges, but it also creates opportunities for innovation and competition, particularly for the chemical industry if the raw material base undergoes a fundamental transformation and Germany establishes itself as a technology leader. 

Another challenge is the presence and formation of microplastic particles and their uncontrolled release into the environment. The significant negative impact of plastics and plastic pollution on ecosystems is recognised and is being mitigated by initial EU-wide regulatory approaches. However, the effects on human health remain largely undocumented and have not yet been systematically researched. Plastics play an important role in many other action areas of the NCES, particularly at the product level. This section focusses primarily on the material level. 

The following regulations and initiatives are already in preparation and provide important frameworks for the objectives of the NCES in the action area plastics. 

EU Packaging and Packaging Waste (PPWR): Under the forthcoming EU Packaging and Packaging Waste Regulation, Member States will be required, as is already the case under the existing Packaging and Packaging Waste Directive (Directive 94/62/EC), to recycle at least 55 percent of plastic packaging by 2030. Additionally, all packaging must be recyclable, with large-scale recyclability becoming mandatory from 2035 onwards. Specific targets are laid down for 2030 and 2040 for recycled content in plastic packaging. The EU Packaging and Packaging Waste Regulation is expected to be adopted by the European Parliament and Council by the end of 2024. The Regulation will enter into force 20 days after publication in the Official Journal and will apply directly in Member States 18 months after its entry into force, except for provisions with different deadlines. Germany’s Packaging Act (Verpackungsgesetz, VerpackG) must therefore be brought into line with the EU regulation by mid-2026. This process must also use the flexibility provided by the PPWR to national legislators.

The Federal Government is developing a Carbon Management Strategy (CMS), which will identify potential applications for carbon capture and utilisation (CCU) as well as the legal and economic frameworks necessary for its successful expansion, including the establishment of the required infrastructure (see Section ‎1.4). The existing pilot plants and processes are energy-intensive due to their substantial hydrogen demand. However, they will play a key role in the transformation of the chemical industry as the availability of green energy increases. Where necessary, they can complement recycled plastic and biomass as sources of raw materials. 

At international level, the Federal Government supports the development of a treaty to end plastic pollution, which is being negotiated under the United Nations. The aim is to establish the foundations for the globally sustainable use of plastics. The Federal Government is advocating globally binding prevention targets, harmonised requirements and the mobilisation of necessary financial resources, particularly from the private sector, to ensure adequate funding. 

Based on the vision of a comprehensive circular economy for 2045 presented in Section 1.3, and complementing the guiding principle and overarching goals formulated in Section 2, the following additional goals apply to this action area:

  • Gradual increase in recycled content derived from post-consumer waste, combined with an expansion of sorting and recycling capacity.
  • Increased use of recycled content in plastic production, broken down by polymer type, for example, polyethylene terephthalate (PET), polypropylene (PP), polyvinyl chloride (PVC) and polystyrene (PS). 

To achieve these goals, the following measures, among others, are required at national or EU level.

Dialogue on material diversity in plastics 

Increasing product requirements have made the development of ever more plastic types necessary. At the same time, placing new plastic variants on the market complicates the collection of unmixed material streams, the establishment of economically viable recycling infrastructure and circularity in plastics. To address this, the Federal Government will initiate a dialogue with industry to encourage the voluntary reduction of material diversity, particularly in the use of thermoplastics. 

Strengthening the share of recycled content in plastics 

In the medium to long term, minimum recycled content targets at EU level will be further developed and supported with the involvement of industry. Minimum recycled content targets must be market-oriented, reliable and not overly bureaucratic, they must send clear market signals and ensure investment certainty. The prerequisites for this are sufficient availability of recycled materials, their quality and consumer acceptance, as well as an accompanying market analysis that also evaluates the possible impacts on competitiveness of minimum recycled content targets. Examples include:

Product-specific minimum shares of recycled content from post-consumer waste to advance circularity in plastics. This would incentivise the development of collection structures, take-back systems and recycling technologies. The selection of product groups and the level of targets is to be determined in dialogue with industry representatives and the scientific community. A prerequisite is that existing quality standards continue to be met, which requires stringent quality controls on imported plastic recycled content. 

Introduction of mandatory shares of recycled materials containing minimal pollutants in plastic production(so-called polymer-specific targets). These targets apply directly to the plastic or polymer itself, regardless of the product. For certain plastic types (for example, PET and PP), these targets specify what percent by weight of production must come from recycled plastic waste in order for it to be permitted on the market in Europe. The market will then determine how recycled content is used in different product applications. The mechanism of such polymer-specific substitution targets can be outlined as follows: they would apply to plastics produced in Germany and Europe as well as to imported plastic products and would be gradually increased. Their introduction must take place across the EU (for example, through an EU Directive) and ensure a level playing field, including for imported products. Trade policy and trade law considerations (WTO law, free trade agreements) must also be taken into account. Mandating a polymer-specific share of recycled content in plastic production will reduce the environmental footprint of plastic products. At the same time, such regulation aims to increase long-term demand for recycled content (pull effect), creating planning certainty and incentives for innovation. The goal is to ensure that downstream value chains are supplied with sufficient quantities of plastics containing recycled content that meet demand (push effect). This approach is also intended to reduce the price-related competitive disadvantages of recycled content. This instrument has an impact across the entire value chain, as distributors and manufacturers of plastic products will be able to plan based on a reliable supply of recycled content and adjust their production accordingly. The target thus stimulates investment in the recycling sector within the chemical and plastics industries, as well as among waste disposal operators and recyclers. In order to keep the regulatory burden as low as possible, particularly at EU level, this concept can apply only to the polymers with the highest sales volumes and the market players with the largest shares. Realistic targets should be clarified through a stakeholder process involving relevant industries and integrating different stakeholder requirements.

Assessing the introduction of a feed-in tariff and developing a model concept for the plastics sector. The level of remuneration could be linked, based on the Carbon Contracts for Difference model, to the reduction of greenhouse gas emissions achieved by using recycled content compared to new plastic production. This would provide lasting support for the competitiveness of recycled plastics. The market would then determine how recycled content is used in different product applications.

Removing barriers to the use of recycled content through standardisation

Efforts should be made to engage in relevant committees in order to initiate standardisation mandates at both national and European level (see Section ‎3.4). The standardisation roadmap coordinated by the German Institute for Standardization (DIN) has highlighted a significant need for both revised and new standards, particularly for plastics. Existing standards primarily relate to mechanical recycling processes and do not adequately reflect all dimensions of the recycling process. According to the Standardization Roadmap Circular Economy developed by DIN, these gaps in standardisation particularly concern pollutants, additives in compounding processes, and chemical analysis related to odour and emissions. Additional standards should focus particularly on developing a standardised approach to life cycle cost assessments, standards for assessing the reusability of plastics and plastic waste, and industry-specific standards for the reusability of plastic packaging. 

Optimised recycling of plastics

The thermal recovery of plastics must be significantly reduced, not only to lower CO2 emissions but also because recycled carbon is essential for transitioning to a fossil-free chemical industry. To achieve this, mechanical recycling processes will be further developed and used more extensively, while chemical recycling will  be established for waste streams that are currently only processed through thermal recovery. 

Design for Recycling will ensure that, wherever possible, materials are used that can be mechanically recycled. For material flows where mechanical recycling is not an option, chemical recycling processes will be supported as a complementary solution. From an industry perspective, the mass balance fuel-use exempt method is considered a prerequisite for investments in chemical recycling. The Federal Government supports this mass balance method and has advocated it in EU-level coordination processes.

Research 

Strengthening the ministerial research of the BMUV, with a particular focus on the rapidly scaling of successful research and pilot projects: 

  • Developments in plastic recycling technologies related to: the quantities and qualities of plastics in various applications, especially for product categories where data on circularity is lacking; metrics and indicators for determining the circularity of plastics; the technological, economic and environmental characteristics of different plastic recycling technologies, including mechanical recycling, enzyme-based processes and chemical decomposition methods; and the handling of composite materials where the use of non-composite materials is not feasible.
  • Use and management of flame retardants in waste from technical plastics, particularly from electrical and electronic equipment, the automotive sector and the construction industry.
  • Data, methods and indicators for the environmental assessment of sorting and recycling technologies.