A special provision applies to final distributors of service packaging: they can buy 'pre-participated' unfilled service packaging from a supplier or wholesaler. In this situation, the supplier or wholesaler has already paid for the packaging's recycling. That is called 'pre-participation'. This option is only available for service packaging. Final distributors placing exclusively service packaging on the German market and buying only pre-participated packaging have to register with the LUCID Packaging Register starting 1 July 2022. They will need to confirm the pre-participated nature of the purchase during the registration process. To do so, they have to check the box that says 'Exclusively pre-participated service packaging' when providing details on their packaging types. (Refer to 'What is service packaging?'). Further information can be found in our 'Service packaging' knowledge base.
Final distributors can request that one of the upstream distributors that delivered the unfilled service packaging to them participate this packaging with a dual system. In this situation, the final distributor should make sure that an upstream distributor has indeed fully complied with the system participation requirement. The supplier/wholesaler is required to provide that confirmation. It should also be noted that the final distributor's system participation requirement for other service, retail or grouped packaging remains unaffected.
Final distributors can also, however, fulfil all of their packaging law obligations themselves: registering with the LUCID Packaging Register, concluding a system participation agreement, submitting data reports on packaging volumes to their chosen system(s) and the LUCID Packaging Register.
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