For printed/publishing products, the producer / initial distributor is generally the publisher or client of the printer where the printed products are produced according to their specifications in terms of both the packaging design (e.g. protective film, catalogue, direct mail packaging) and the design of the printed products. In these cases, it is the publisher or client of the printer who is subject to registration and system participation.
It is important that registration and system participation take place before the printed products are placed onto the German market.
The packaging of printed/publishing products is only subject to system participation when they are classified as goods. In the case of, for example, invoices or direct mail sent in envelopes it can be unclear whether they qualify as goods or not. Here, the question is whether the focus is on transmitting a notional content (in this case the document does not qualify as goods) or on the physical aspect (in this case it does qualify as goods).
Further information can be found in our informational booklet on documents, papers, magazines, etc. FAQ: documents, papers, magazines, books, manuals, direct mail, advertising brochures, etc. Delineation between goods/non-goods for the categorisation of packaging FAQ: documents, papers, magazines, books, manuals, direct mail, advertising brochures, etc. Delineation between goods/non-goods for the categorisation of packaging
Everything at a glance: You will find all answers to all common questions in our overall FAQ: