Having packaging classed as being subject to system participation (section 54 (1) no. 33 VerpackDG): the application procedure

This page contains important information about how to submit an application.

In order to prepare for the large number of expected classification decisions, the Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR) has decided to publish norm-interpreting administrative regulations. These contain indications of how the ZSVR would likely decide an application concerning the classification of packaging as being subject to system participation. For ease of use, the administrative regulations are published in the form of a system participation requirement catalogue.

What you need to know

  • All decisions are made on a case-by-case basis (e.g. for a specific unit of packaging). No decisions can be made for

    • entire product portfolios, 

    • groups of goods / product groups, or

    • delivery lists.

  • General obligations under the EU Packaging and Packaging Waste Regulation (PPWR) and the German Packaging Law Implementation Act (VerpackDG), including 

    • owhether a company is required to register or

    • the extent of a producer's system participation requirement cannot be clarified through a classification application.

  • Packaging material that does not constitute complete packaging or cannot be classified under any specific type of packaging (for example, shrink film on rolls) cannot be the subject of a classification application. 

  • The ZSVR does not provide any legally binding information beyond the scope of its statutory duties, including 

    • the recyclability of a packaging unit or material,

    • the conformity of a packaging unit, and

    • the labelling of a packaging unit in accordance with packaging or food law.