In essence, every responsible party in the packaging chain is affected. A manufacturer of packaging has to consider, for example, material, design and labelling-related requirements for the packaging.
Any party who is the first to place retail or grouped packaging filled with goods that typically accumulates with private final consumers onto the German market is a 'producer of packaging subject to system participation' and is therefore required to register with the Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR) and undertake participation with one of the waste management systems approved by the competent state authorities (often called a ‘dual system‘; the Verpackungsgesetz calls them ‘systems‘).
Any party that produces service packaging can be required to undertake participation for this packaging with one of the systems by the final distributor of the packaging (the party who fills the service packaging with a good and hands it over to a consumer, e.g. sandwich bags at a bakery, to-go containers at a fast food restaurant).
For transport packaging, the requirements begin at an earlier distribution phase: a producer of transport packaging must meet return and recovery requirements. This assumes that the usage is already known during production. In many situations, however, this may not be the case: return and recovery requirements then begin when the packaging is filled.
Any party who is the first to place transport, retail or grouped packaging onto the German market that accumulates in industrial or large commercial enterprise settings is deemed to be a 'distributor' and is obliged to return and recover the packaging.
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