No, that is not possible. The Verpackungsgesetz (Packaging Act) is intended in particular to be favourable to small artisanal food production businesses, small takeaway food providers and small distributors. They are able to shift the system participation requirement and require a wholesaler or manufacturer to undertake system participation. However, that party in turn does not have a right to shift the requirement onward. Rather, the wholesaler or manufacturer assumes the responsibilities of the 'producer' not only in terms of system participation, but also with regard to volume reporting to the Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR).
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