General Association of the Plastics Processing Industry (GKV)
A growth agenda for Germany
Positions of the Gesamtverband Kunststoffverarbeitende Industrie e.V. (GKV)
for the 2025 federal election
Germany needs a new growth agenda
There are structural reasons for the accelerating deindustrialization of the SME sector. In addition to measures to be taken in the short term, the new German government must also change inadequate framework conditions, otherwise it will not be possible to stop the exodus of industrial SMEs. The transformations with the goals of greenhouse gas neutrality and a circular economy require high investments from companies, which will only be made if the companies see a long-term perspective for themselves in Germany. Predictability and reliability must once again become the maxims of economic policy; but it also takes courage and determination to cut out old (bureaucratic) habits and work together with business and industry to sustainably strengthen the location. Germany therefore needs a new growth agenda that takes up at least the following proposed solutions:
1) Energy and climate
The plastics processing industry is electricity-intensive and faces international competition. Companies’ costs for electrical energy in Germany have not been competitive for several years.
– The expansion of the grid to integrate renewable energies and the provision of additional
power plant capacity must not make electricity even more expensive for industrial consumers.
levies at the expense of electricity consumers have already been an extremely expensive
mistake in the past. Energy-intensive SMEs need an
electricity price cap in the form of an all-in production electricity price that is designed to last for several years.
– National climate targets that go beyond the climate path agreed in the European Union must be avoided.
– Germany must be open to all forms of sustainable energy supply. In order to be able to generate and use energy in an internationally competitive manner in the long term, energy research must be driven forward in all directions.
– Accelerated procedures and simpler rules for the commissioning of green energy systems on company premises could also significantly advance the sustainable transformation of the SME sector
.
2) Labor and skilled workers
Large parts of Germany’s SME industry have been experiencing a considerable shortage of skilled technical workers in particular for years. Since the coronavirus years at the latest, the shortage of skilled workers has become a shortage of labor. Although the economic crisis is currently causing job losses in individual sectors, additional skilled workers are still needed to ensure that growth is possible again despite demographic trends.
– In future, immigration to Germany must be more closely aligned with the demand for skilled workers.
– Non-wage labor costs must not be allowed to rise any further.
– It is of immense importance that good framework conditions are consistently combined with a digitalization strategy for SMEs. Digital technologies and artificial intelligence, closely networked with existing and potential future automation steps, will enable SMEs to get by with significantly fewer workers and specialists.
– The ability of young people to train at the end of their school career must be the clear and common goal of politics and society. Technical professions are also often the driving force behind integration, and medium-sized plastics processing companies should receive more support and recognition for their training efforts, for example through a training pact.
– The integration of migrant workers into the labor market and the recognition of professional qualifications acquired abroad must be simplified and accelerated.
3) Circular economy
The plastics industry in Germany is making enormous efforts to transform the industrial sector into a circular economy. The current economic crisis threatens to put the brakes on this important transformation.
– Incentives for more recyclable packaging cannot be delayed any longer. This is why the reform of Section 21 of the Packaging Act must be adopted at the beginning of the legislative period. The regulation should create a private-law fund under the responsibility of the Central Agency Packaging Register and be easy for companies to comply with. The involvement of the Federal Environment Agency must be avoided at all costs in order to avoid problems under financial constitutional law (keyword: special levy) and the application of EU state aid law.
– The implementation of the EU Packaging Regulation requires a decision right at the beginning of the legislative period on how manufacturers of packaging that is not subject to system participation (e.g. industrial transport and hazardous goods packaging, reusable packaging) can fulfill their producer responsibility.
– The Federal Environment Agency’s responsibility for managing the Single-Use Plastic Fund has not proven to be effective. If the Federal Constitutional Court classifies the EWKFondsG as unconstitutional, the new regulation should be implemented by the private sector, as in other EU Member States, and with the involvement of the Central Agency Packaging Register.
– The proportion of plastic waste that is processed into high-quality recyclates is still too low. In order to make better use of this resource potential, plastic waste in residual household waste and commercial waste in particular must be better sorted and larger quantities must be sent for high-quality recycling. The German government must take the initiative here.
– The German government is working at European level to create a functioning market for recycled plastics in which fossil-based virgin plastics are gradually replaced by recyclates and non-fossil-based plastics. To this end, the German government is particularly committed to the introduction of polymer-specific substitution quotas and certificate trading for recycled plastics.
– At the same time, the German government is working in Brussels to ensure that the import of recycled plastics from third countries remains possible in accordance with the rules of international trade law.
– Modern reusable solutions promote resource conservation and reduce greenhouse gases. Plastics offer a wide range of solutions here, which could be flanked by political instruments such as a stronger focus on resource efficiency in public procurement.
4) Bureaucracy and Europe
The flood of ever new and ever more detailed legislation and reporting obligations is almost impossible for the vast majority of SMEs to cope with and is increasingly unsettling companies. Additional reporting and verification obligations arise for companies from the Supply Chain Duty of Care Act, the Energy Efficiency Act, the Single-Use Plastics Fund Act, the taxonomy, the CSRD and many other regulations. More and more bureaucracy does not create more innovation, but rather jeopardizes the existence of companies. Moreover, SMEs are no longer able to reliably manage the complex application procedures for cost reimbursements of energy levies and the associated additional obligations to provide evidence. Applications under EnFG, StromStG etc. are symptomatic of overregulation and a lack of reliability.
– In many cases, Germany has additionally tightened EU environmental, climate and energy regulations in its national implementation. A prominent example of this is the German Supply Chain Duty of Care Act. This “gold plating” must now come to an end. Uniform conditions for the implementation of EU law are necessary to ensure a level playing field in the internal market.
– The barely comprehensible flood of detailed regulations in German energy and climate protection law is paralyzing the transformation. The regulatory content of energy and climate protection law must be limited to the minimum level required under European law.
– The restriction dossier on the PFAS substance group, which was also initiated by Germany, must be withdrawn immediately. The individual PFAS groups should be assessed in a differentiated and risk-based manner.
Undifferentiated and inappropriate restrictions on fluoropolymers, which belong to the PFAS group, would increase Europe’s dependence on high-performance plastics, while the objectives of the Green Deal would hardly be achievable.
– The new German government must lobby the European Commission to abolish at least half of all regulations within the new term of office of the Commission
. New laws, directives, regulations and delegated acts of the European Union and the federal government should generally only be valid for five years in future.
– In addition, there is often no level playing field between
German/European manufacturers and non-European manufacturers due to deficiencies in enforcement. Many products that reach the
EU market do not comply with the strict environmental, climate protection and safety regulations that the European Union imposes on itself – and which, in turn, are met by European suppliers. There is an urgent need to improve controls at the external customs borders, as otherwise local producers will be at a permanent disadvantage due to additional requirements and the associated higher costs.
5) Budget and finances
– Despite the economic crisis, federal tax revenues remain at record levels. The federal government is setting the wrong priorities when it comes to spending.
– It makes no sense for consumers to be asked to pay part of Germany’s membership fee to the European Union via a new additional plastic tax. Reaching into consumers’ pockets will improve neither the economy nor the environment. The new German government must abandon plans for a nonsensical, anti-social and harmful plastic tax.
– The solidarity surcharge will also be abolished immediately for companies.
– In order to overcome the reluctance of SMEs to make private investments, federal funding for the implementation of digital technologies and environmentally friendly processes will be geared towards SMEs.
– We are calling for a relaunch of federal funding for climate-friendly and innovative lightweight construction technologies.
Berlin, November 2024
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