Any time a transfer to a third party in the course of business actually occurs, this is considered to be 'placing on the German market' or 'distribution' within the meaning of the Verpackungsgesetz (Packaging Act). It is immaterial whether the transfer is in exchange for money or not. Registration and system participation (where applicable) is required, for example, for sample goods or giveaways or other complementary transfers of packaged goods, as long as this occurs as part of the practice or promotion of a commercial activity. This includes every transfer that occurs in the course of product distribution. The critical factor is that a third party takes possession of the packaging.
Everything at a glance: You will find all answers to all common questions in our overall FAQ: