No, that is not possible. The possibility to pass on the system participation requirement serves to reduce the burden especially for small and medium-sized artisanal food production businesses. In the case of service packaging, they are able to shift the system participation requirement and require an upstream distributor (e.g. the supplier of such packaging) to undertake system participation. However, that party in turn does not have a right to shift the requirement onward. Rather, the upstream distributor assumes the responsibilities of the 'producer' not only in terms of system participation, but also with regard to registration and volume reporting to the Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR).
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