No. Filling will also be considered to have taken place on the premises of the final distributor if the packaging was not filled directly at the point of sale, but in the nearby vicinity, e.g. in a separate production or work room adjacent to the sales area. The criterion of 'nearby vicinity' is fulfilled if the filling and handing over to the final consumer takes place at the same premises of the final distributor, or up to a few hundred metres from there. It is generally not fulfilled if the filled packaging was transported on a public road between the point of filling and the point of sale / point of handing over to the final consumer. As an example: where packaging is filled centrally and then transported to various branches, 'nearby vicinity' no longer applies. That is to say, the packaging is not classed as service packaging.
Further information about the 'nearby vicinity' criterion can be found in the following informational booklet. FAQ: on 'nearby vicinity' as applies to service packaging (English link coming soon.)
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