The Verpackungsgesetz (Packaging Act) also contains provisions for the production of packaging, e.g. restrictions on substances (section 5) or regulations on labelling packaging (section 6). These provisions apply to empty packaging and therefore the manufacturers of the packaging.
Since the registration and system participation requirements are predicated on filling packaging with goods, they do not apply to manufacturers who place empty packaging onto the German market (with the exception of transport packaging and packaging for industrial and large commercial enterprises – see below).
Service packaging is subject to special arrangements. For service packaging, the party filling it and handing it over to final consumers for the first time can request that an upstream distributor undertake registration and participation in a waste management system for the service packaging (to 'What is service packaging?').
The return and recovery requirements for transport packaging and for retail and grouped packaging that typically accumulates as waste in industrial and large commercial enterprise settings also apply to the producers/distributors of empty packaging.
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