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Impact of the 25g Hookah Tobacco Regulation on Packaging Waste
Last updated on 25.06.2024 | Reading time approx. 04:42min

Pipe tobacco is the only type of tobacco that has shown consistent sales growth in recent years. This is evident from data provided by the Federal Statistical Office (www.destatis.de). The following chart, an excerpt from the Fachserie 14 Reihe 9.1.1, shows the annual growth rates of this segment.

Annual Growth Rates of Pipe Tobacco, Fachserie 14 Reihe 0.1.1, Federal Statistical Office
The data from the office also reveals that these growth rates are largely attributable to hookah tobacco, which is why it has been listed separately in the statistics since 2022.
The Recent Legislative Changes and Their Reasons
Until the end of 2021, tobacco manufacturers could still obtain tax stamps for packaging sizes containing more than 25g of hookah tobacco, and production of these packaging sizes was permitted until mid-2022. Starting in July 2022, only the production of packaging with a maximum content of 25 grams is allowed.
The main reason for this legislative change is that hookah bars have been acting unlawfully by selling a portion of tobacco (around 20 grams) taken from a 200g can. According to the law, the tobacco must be sold at the retail price printed on the tax stamp, including the entire packaging content.
Consequently, only packaging containing 20g or 25g is permitted. However, many hookah tobacco manufacturers did not offer these sizes, leading hookah bar operators to use 200g or 1000g packaging for cost reasons. To prevent this, the new law has come into effect, allowing only packaging sizes with a maximum of 25g.
The New Situation with 25g Packaging
With this legislative change, even private consumers who enjoy hookah at home must now purchase 25g packages. This is not only annoying when preparing the hookah but also generates a significant amount of packaging waste.
Most tobacco varieties come in cardboard boxes wrapped in plastic. Inside the cardboard box, the tobacco is also sealed in a plastic bag to ensure airtight packaging. Additionally, some manufacturers have switched from large cans for their 200g packaging to small plastic cans for the 25g units.
Based on our own data, the current distribution of these two packaging variants is approximately 75% cardboard boxes and 25% plastic cans.
Assumptions for Calculating Packaging Waste
To assess the difference in packaging waste, we first need to make a few assumptions:
- Hookah tobacco sales remain at the same level as the previous year. This is a conservative assumption, as growth rates in recent years have typically ranged between 20% and 40% per year. On the other hand, the new law also comes with a price increase, which may dampen sales somewhat.
- The data from the Federal Statistical Office does not specify the proportion of different packaging sizes in previous years. Here, we rely on our own sales data and have cross-checked it for plausibility with the distribution of stamp prices from the Federal Statistical Office data. We estimate that around 82% of sales were in 150g/200g/250g sizes, with 200g making up the majority. The cans for these sizes are almost identical in size. 1000g cans account for 11%, and the remaining 7% consists of other packaging sizes, which we will disregard in this calculation.
- The tax stamps issued for pipe tobacco in 2021 correspond to a quantity of 8,538 tons. It is assumed that a large portion of this quantity is attributable to hookah tobacco, although many other products now fall into this category, such as IQOS Heatsticks or vapor stones. Therefore, we conservatively estimate 60%, resulting in a production of 5,122.8 tons for 2021.
Calculation of Packaging Waste
Based on the assumptions above, we estimate that the hookah tobacco produced in 2021 was distributed across the following packaging sizes:
- 21,003,480 cans with 200g content
- 563,508 cans with 1000g content
With a new packaging size of 25g, the same quantity of tobacco would require 204,912,000 cans. To calculate the impact on packaging waste, we weighed empty cans from various manufacturers to determine an average weight for each packaging size and thus estimate the total weight of packaging materials. Plastic cans for 25g packaging weigh an average of 22g. Cardboard box packaging with an inner plastic bag has an average total weight of 9g, with 6g attributable to the cardboard and about 3g to the plastic component.
Given a packaging distribution of 75% cardboard boxes and 25% plastic cans, the following quantities of packaging material result:
Cardboard Box Packaging:
75% * 204,912,000 = 153,684,000 (number of cardboard box packages per year)
153,684,000 * 0.009kg = 1,383,156kg = 1,383.2t (packaging waste: cardboard + plastic)
The waste is divided as follows between plastic and cardboard:
153,684,000 * 0.006kg = 922,104kg = 922.1t (cardboard waste)
153,684,000 * 0.003kg = 461,052kg = 461.1t (plastic waste)
Plastic Can Packaging:
25% * 204,912,000 = 51,228,000 (number of plastic can packages per year)
51,228,000 * 0.022kg = 1,127,016kg = 1,127t (plastic waste)
The total weight of all packaging materials is therefore 2,510.2t.
Calculating the packaging waste for 200g cans is not as straightforward, as some manufacturers use cans made of cardboard coated with a "protective film," while others use pure plastic cans. For the cardboard-based cans, the protective film is made of plastic. The two materials are tightly bonded, making it difficult to weigh them separately. For this reason, we decided to calculate the total packaging waste without separating the materials.
A 200g can weighs an average of 52.5g.
21,003,480 * 0.0525kg = 1,102,683kg = 1,102.7t (packaging waste: plastic + cardboard)
A 1000g can weighs an average of 148.5g. Thus, for the previously estimated 563,508 cans, the packaging weight is:
563,508 * 0.1485kg = 83.7t (packaging waste: plastic + cardboard)
This results in a total weight of 1,186.4t for the old packaging.
Comparison of Packaging Waste: 2021 vs. 2023
Comparing the two total quantities of packaging waste, we have 1,186.4t for the 200g and 1000g cans versus 2,510.2t for the 25g cans. The packaging waste generated by hookah tobacco has more than doubled due to the legislative change.

Comparison of Hookah Tobacco Packaging Waste, 2021 and 2023
Conclusion
We find it alarming that, in this day and age, a law is changed in such a way that packaging waste increases so drastically. The additional waste generated is equivalent to the amount produced by 16,969 people in German households per year! (Source: DESTATIS)
Related Posts
Consequences of new 25 gram hookah tobacco law in Germany on the environment Advantages of the new 25 gram hookah tobacco law in Germany Hookah Black Friday - The biggest sale of the year for hookah and accessories!Author

Nils
The nice guy for even nicer content.