What applies in 2027
| Cost driver or rule | Value | Status |
|---|---|---|
| CO2 price under the Brennstoffemissionshandelsgesetz (Fuel Emissions Trading Act) | Corridor of €55 to 65 per tonne, as in 2026 | passed by the Bundestag |
| EU emissions trading for buildings and transport | does not start until 2028 | postponed |
| Packaging law (VerpackDG) | in force since 12 August 2026; transition for packaging outside private households until 31 December 2027; fines for breaching EU Regulation requirements from 12 February 2027 | in force |
| Gewerbeabfallverordnung (Commercial Waste Ordinance) | collect separately and document, pre-treat mixed waste, at least one residual waste container from the public waste disposal authority | in force |
| Diesel for collection vehicles | Energy tax cut on fuels of 14.04 cents per litre ends on 31 December 2026 | temporary |
| Statutory minimum wage | €14.60 from 1 January 2027 (+5.0%) | adopted |
Waste incineration is part of the national emissions trading system. If the 2027 corridor stays unchanged, as decided by the Bundestag, it does not justify a higher CO2 surcharge than in 2026. For the collection vehicles, however, diesel is what counts: if the tax cut ends as planned, the energy tax will rise again by 14.04 cents per litre at the turn of the year.
What makes up the price
Commercial waste has two pricing systems. Residual waste that is not recovered must be handed over to the public waste disposal authority. For this, § 7 GewAbfV requires you to use the authority’s containers to an appropriate extent, as specified by the authority, but at least one. The cost is a fee under your municipality’s bylaws.
Everything else you award by contract: container rental, emptying or collection, transport, recovery per tonne and, for paper and cardboard, a payment for the recyclable material. Delivery notes and weighbridge tickets matter twice over: as proof of separate collection and as the basis for any billing by weight.
What the Commercial Waste Ordinance requires
- Collect separately: paper, cardboard and paperboard, glass, plastics, metals, wood, textiles and bio-waste (§ 3). Exceptions apply only if separation is technically impossible or economically unreasonable.
- Document: that you collect separately, for example with site plans, photos or delivery notes and weighbridge tickets, and that the waste is recovered, with a declaration from the waste contractor. The authorities can request these records.
- Pre-treat mixed waste: waste that arises mixed must go to a pre-treatment plant (§ 4). The obligation does not apply if you collected at least 90% separately in the previous year; an expert confirms this by 31 March.
- Hand over residual waste: at least one container from the public waste disposal authority (§ 7).
Six points where waste disposal contracts become too expensive
- Containers and frequency out of habit. Large containers collected half empty, and fixed collections without regard to quantities. Choose size and frequency based on the actual fill level.
- Residual waste containers beyond what is needed. The appropriate extent is set by the bylaws of your public waste disposal authority. Check what minimum volume they require and whether your containers exceed it; if you separate consistently, you need less residual waste volume.
- Recyclables without payment. Cardboard and plastic film have a market value. Without an agreed payment with grade, index, deduction and floor price, the revenue stays with the waste contractor. Balers compact the material and reduce the number of collections.
- Mixed waste instead of separation. Mixed waste must be pre-treated and is harder to recover. Separation is both an obligation and a lever.
- Surcharges without a formula. Flat-rate climate, energy or diesel surcharges with no reference basis. Link a CO2 component to the price corridor of national fuel emissions trading and a diesel share to a published price, in both directions.
- A separate contract for every branch. Different prices, contract durations and notice periods at each site. A framework agreement with a uniform service specification creates comparability. Between businesses, automatic renewals are largely permissible, so monitor the deadlines yourself.
Packaging: what changes by the end of 2027
The VerpackDG, which supplements the EU Packaging Regulation in Germany, has applied since 12 August 2026. For packaging that is not subject to mandatory system participation, i.e. packaging that arises neither at private households nor at comparable points of generation, producers will need a producer responsibility organisation or their own authorisation from the Zentrale Stelle Verpackungsregister (Central Agency Packaging Register). Without one, they may make such packaging available until 31 December 2027 at the latest. Fines for breaching the requirements of the EU Regulation apply from 12 February 2027. If your waste disposal or take-back contracts run beyond 2027, agree now who will bear the new costs.
Before you agree to an increase
Ask your service provider in writing:
- How often is each container emptied, and how full is it on average?
- What payment do we receive for paper, cardboard and plastic film, and based on which index?
- Which surcharges do you charge, using which formula and on what basis?
- Do you provide weighbridge tickets, delivery notes and the records required under the Commercial Waste Ordinance?
- How will your costs change as a result of the new packaging law, and from when?
For the review, you need: the contracts and price sheets for each site, collection records, weighbridge tickets and delivery notes, the invoices for the last twelve months and the fee notices from your municipalities.
How we renegotiate waste disposal contracts
We reconcile invoices, weighbridge tickets and collections for each site, check containers and frequency against the quantities, and the payment for recyclables against the market. We link surcharges to formulas that can also go down. Our senior negotiators handle large contracts in person, together with your buyer. We process the many small contracts in a standardised, software-supported way, following your rules. You approve every deal.
Frequently asked questions about waste disposal
Do we need the municipal residual waste bin if a private contractor collects everything?
Yes, for commercial municipal waste that is not recovered. For this, § 7 of the Commercial Waste Ordinance requires containers from the public waste disposal authority to an appropriate extent, as specified by the authority, but at least one. The obligation does not apply if the authority has excluded this waste from its disposal service.
What do we have to document for separate collection?
That you collect separately, for example with site plans, photos or delivery notes and weighbridge tickets, and that the waste is recovered, with a declaration from the waste contractor stating name, address, quantity, type of recovery and final destination. If you depart from the separation requirement, you must give reasons. The authorities can request these records; missing documentation is an administrative offence.
Will the CO2 price rise in 2027?
Probably not. On 15 October 2026, the Bundestag decided that the 2027 corridor will remain at €55 to €65 per tonne, as in 2026; the procedure in the Bundesrat is still pending. EU emissions trading for buildings and transport does not start until 2028. Waste incineration is part of the national emissions trading system.
What is changing for packaging in business-to-business trade?
The VerpackDG has applied since 12 August 2026. For packaging that is not subject to mandatory system participation, producers need a producer responsibility organisation or their own authorisation; the transition period runs until 31 December 2027. Fines for breaching the requirements of the EU Packaging Regulation apply from 12 February 2027.
How do we agree fair payment for waste paper?
With grade, index, reference month, deduction and floor price. The trade information service EUWID publishes monthly price changes for nine grades of waste paper. The service is subscription-based, so agree who discloses the figures.
Sources
- Gewerbeabfallverordnung (Commercial Waste Ordinance)
- German Bundestag: hearing and decision on the Third Act amending the Brennstoffemissionshandelsgesetz (Fuel Emissions Trading Act), 15 October 2026
- IHK Schwarzwald-Baar-Heuberg (Chamber of Industry and Commerce): VerpackDG and PPWR
- Fünfte Mindestlohnanpassungsverordnung (Fifth Minimum Wage Adjustment Ordinance)
- EUWID: Altpapier Deutschland (waste paper, Germany), market reports (subscription required)
- EY: Tankrabatt 2.0 (fuel tax cut), May to June 2026
- AUTO BILD: Energy tax cut since 1 October 2026
