A 'producer' in this context means:
- any party who fills and places onto the German market for the first time empty packaging that typically accumulates with private final consumers (initial distributor);
- any party who imports packaged goods into Germany that typically accumulate with private final consumers, and places them here onto the market for the first time (importer); this can be
- any party located abroad that ships the goods to Germany;
- any party located in Germany that orders the delivery.
As a general rule: the party who bears legal responsibility for the goods at the time they cross the border is the 'importer'.
- any party in the mail order company sector who fills and places onto the German market for the first time shipment packaging that typically accumulates with private final consumers (mail order companies or online retailers);
- in the case of service packaging, the final distributor of this packaging can also request, as an exception, that the manufacturer / initial distributor of the empty packaging bears the system participation requirement.
A producer is not required to register if they produce packaging and place it onto the German market as empty packaging.
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