Consequences of new 25 gram hookah tobacco law in Germany on the environment

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

Jährliche Wachstumsraten Pfeifentabak, Fachserie 14 Reihe 0.1.1, Statistisches Bundesamt — Annual growth rates for pipe tobacco, Fachserie 14 Reihe 0.1.1, Federal Statistical Office

It is also clear from the Office's data that these growth rates are largely attributable to waterpipe tobacco, which is why this is now also listed separately in the statistics from 2022.

The current legislative changes and the reasons for them

Until the end of 2021, tobacco manufacturers were still able to obtain tax stamps for pack sizes containing more than 25g of hookah tobacco and the production of these pack sizes was permitted until mid-2022. From July 2022, only the production of packaging with a maximum content of 25 grams will be permitted.

The main reason for this change in the law is that hookah bars are breaking the law by selling a ration of around 20 grams of tobacco taken from a 200g tin. According to the law, the tobacco must be sold with the entire contents of the packaging at the retail price. The retail selling price is the price printed on the tax stamp.

Accordingly, only packs containing 20g or 25g are permitted. However, these were not even offered by many hookah tobacco manufacturers, so that hookah bar operators resorted to 200g or 1000g packaging for this reason and also for cost reasons. In order to prevent this, the law has now come into force, according to which only packaging sizes with a maximum of 25g are permitted.

@mozeshisha
Shisha tobacco 25g law - packaging waste?!
♬ Originalton - Moze Shisha

The new situation with 25 g packaging.

The change in the law means that every private consumer who wants to enjoy their hookah at home now has to buy 25g packaging. This is not only annoying when preparing the hookah, but also creates a large amount of packaging waste.

Most types of tobacco are packaged in a cardboard box, which is sealed with plastic on the outside. In this cardboard box, the tobacco is also sealed in a plastic bag so that it is packed airtight. There are also manufacturers who have switched from large tins for their 200g packaging to small plastic tins for the 25g packaging units.

Based on our own data, the current share of these two packaging variants is around 75% for cardboard boxes and 25% for plastic tins.

Assumptions for the calculation of packaging waste

In order to assess the difference in packaging waste, we first need to make a few assumptions:

Sales of waterpipe tobacco will remain at the same level as in the previous year. On the one hand, this is a conservative assumption, as growth rates in recent years have generally been between 20 and 40 percent per year; on the other hand, the new law is also accompanied by a price increase, which may dampen sales somewhat.
The data from the Federal Statistical Office does not show exactly how high the proportion of different packaging sizes was in previous years. Here we have used our own data from sales and checked it for plausibility with the distribution of sleeve prices of the issued sleeves from the data of the Federal Statistical Office. We arrive at a share of around 82% for 150g/200g/250g, with 200g accounting for the lion's share and the cans of these sizes being almost identical in size. The 1000g cans account for 11%. The remaining 7% is made up of other packaging sizes, which we will ignore in this calculation.
The tax stamps obtained for pipe tobacco in 2021 relate to a quantity of 8538 tons. It can be assumed that a large part of this quantity is attributable to water pipe tobacco, even though there are now many products that fall into this category. These also include products such as IQOS heatsticks and vapor stones. Accordingly, we conservatively calculate 60% here. This results in a production of 5122.8 tons for 2021.

Calculation of the packaging waste generated

Based on the above assumptions, we assume that the hookah tobacco produced in 2021 will be divided into the following pack sizes:

21.003.480 Tins with 200g content
563.508 Tins with 1000g content

With a new packaging size of 25 g, we arrive at a quantity of 204,912,000 cans for the same amount of tobacco. In order to calculate the impact on packaging waste, we took empty cans from different manufacturers and weighed them to determine an average value for each packaging size and thus calculate the total weight of the packaging material. Plastic cans in packaging containing 25 g have an average weight of 22 g. Packaging with a cardboard box and an inner plastic bag have a total weight of 9 g on average, with 6 g attributable to the cardboard box and around 3 g to the plastic content.

Accordingly, a packaging ratio of 75% cardboard boxes and 25% plastic cans results in the following quantities of packaging material:

Cardboard box packaging:

75% * 204.912.000 = 153.684.000 (Number of packages with cardboard box per year)

153.684.000 * 0,009kg = 1.383.156kg = 1.383,2t (cardboard + plastic packaging waste)

The waste is divided into plastic and cardboard as follows:

153.684.000 * 0,006kg = 922.104kg = 922,1t (Cardboard packaging waste)

153.684.000 * 0,003kg = 461.052kg = 461,1t (Plastic packaging waste)

Plastic can packaging:

25% * 204.912.000 = 51.228.000 (Number of packages with plastic cans per year)

51.228.000 * 0,022kg = 1.127.016kg = 1.127t (Packaging waste Plastic)

The total weight of all packaging materials is therefore 2510.2 tons.

With 200g cans, the calculation of packaging waste is not quite so simple, as some manufacturers use cans that are made of cardboard but have a "protective film". Other manufacturers, on the other hand, use pure plastic cans. The protective film is made of plastic on cans that are mainly made of cardboard. The two materials are very strongly bonded together, which makes it difficult to weigh them separately. For this reason, we have decided to calculate the total packaging waste and not to separate it.

The average weight of the packaging for a 200g can is 52.5g.

21,003,480 * 0.0525kg = 1,102,683kg = 1,102.7t (packaging waste plastic + cardboard)

For a 1000g can, the average weight of the packaging is 148.5g. This results in the following packaging weight for the 563,508 cans determined above:

563,508 * 0.1485kg = 83.7t (packaging waste plastic + cardboard)

This results in a total weight of 1,186.4 tons for the old packaging.

Comparison of packaging waste: 2021 vs 2023

If we now look at the two total quantities of packaging waste generated, the 200g and 1000g tins weigh 1,186.4 tons compared to 2510.2 tons for the 25g tins. The packaging waste generated by hookah tobacco has therefore more than doubled as a result of the change in the law.