Foundation & Authority

Application procedure to determine whether packaging is classed as being subject to system participation (section 26 (1) no. 23 VerpackG)

On this page you will find important information about making an application to determine whether packaging is classed as being subject to system participation.

In order to prepare for the large number of expected classification decisions and to save producers within the meaning of section 3 (14) Verpackungsgesetz (Packaging Act) (initial distributors) the time and effort of having to make case-by-case applications, 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 a type 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.

Please read our fact sheet ​​​​​and the following information carefully. 

  • Please do not send test items that have been used.
  • All of our decisions are made on a case-by-case basis. General requirements under the Verpackungsgesetz cannot be pronounced by the ZSVR, that means neither 
    • whether a producer is required to register, 
    • the extent of a producer’s system participation requirement
    • nor whether one is required to submit data reports.
  • Only individual, specific test items (packaging containing goods) can be assessed, that means neither 
    • product portfolios,  
    • goods/product groups nor
    • delivery lists.
  • Packaging material alone (without goods) is not an acceptable test item and cannot be assessed if sent unfilled, that means neither
    • boxes,
    • films nor
    • labels.
  • Goods alone (without packaging) are also not acceptable test items, that means neither
    • raw materials (e.g. malt, aluminium),
    • products (e.g. hair dryer, garden sheers) nor
    • goods (e.g. contact lens solution, gelatine).
  • The ZSVR does not issue any other legally binding information beyond what is provided for by law, that means neither
    • individual or general material classifications apart from the classification of hazardous contents nor
    • classifications regarding how recyclable an article of packaging or material is.
  • The ZSVR does not make any decisions about labelling, that means neither
    • food law labelling on packaging,
    • packaging law labelling on packaging nor
    • any other text on packaging.

You can access the application form (form EO23/19) here (only available in German).

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