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5.2 Does the registration requirement also apply to the distribution of goods in used packaging?

Starting 1 July 2022, the registration requirement will apply to all packaging that has been filled with goods – regardless of whether it is used packaging or not. Whenever packaging is commercially filled with goods for the first time, the filler is considered to be the producer. This means that the filler has to register with the LUCID Packaging Register and indicate the packaging type.

If used packaging is placed on the German market for the first time, for typical use with private final consumers, then its initial distributor must register and participate the used packaging in a system. Only where distributors have definite evidence that the packaging they are using has already undergone system participation does the system participation requirement fall away.