A special case – all about pre-participated service packaging

If you are using service packaging to place your goods on the German market, there is a special provision that you can make use of: you can buy 'pre-participated' unfilled service packaging from a supplier or wholesaler. In this case, the supplier or wholesaler has already participated the packaging with a system. In other words: the supplier or wholesaler has already paid for that packaging's recycling.

For the purposes of pre-participation, the service packaging's material or material combination is irrelevant (paper, plastics, metal, glass, paper composites, plastics composites, etc.).

What to do when making use of the special provision

Even if you make use of the special provision, you still have to register with the LUCID Packaging Register. You are also required to confirm you have purchased pre-participated service packaging.

If you only place pre-participated service packaging on the German market (and no other packaging subject to system participation that you would have to participate with a system yourself), check the box 'Exclusively pre-participated service packaging' when entering your packaging details.

It is important that the supplier or wholesaler confirms that you bought pre-participated unfilled service packaging, e.g. on the invoice or delivery note. That allows you to provide evidence that the upstream distributor has taken care of paying for recycling and that you have fully complied with your obligations under packaging law. It also means that you do not have to report your volumes for that packaging.

You can require an upstream distributor to participate unfilled service packaging with a system, effectively paying for that packaging's recycling. This will have an impact on the purchase price. The supplier or wholesaler is required to confirm that you have indeed purchased pre-participated packaging.

Then you will have to fulfil the statutory obligations for service packaging yourself.

Find out more

Placing service and other packaging subject to system participation on the market

The special provision applies only to service packaging. If you are also using retail, grouped or shipment packaging to distribute your goods, you need to participate them with a system. There are three things you need to do to fulfil all of your obligations under German packaging law:

  1. Register with the LUCID Packaging Register. During the registration process, select the topmost category of packaging subject to system participation: 'Retail, grouped or shipment packaging that typically accumulates as waste in private households / comparable sources of waste generation after use, and service packaging'.

  2. Enter into a system participation agreement with a system operator. Please refer to this list for an overview of system operators.

  3. You now have to regularly report your packaging volumes to both your system operator and the LUCID Packaging Register (data reporting).

Heads-up: Check out our packaging types knowledge base for more information.

If you need more information so you can take care of all your obligations yourself, you will find everything you need to know here:

Registration

Every company that distributes packaged good commercially on the German market or imports packaged goods into Germany has to register with the LUCID Packaging Register, regardless of where in the world that company is based.

System participation & data reporting

The following obligations apply to packaging subject to system participation: you will need to register with the LUCID Packaging Register, conclude a system participation agreement and regularly report packaging volumes (data reporting).

Packaging types and categories

System participation – yes or no? What types of packaging are there? What are the obligations that come with each of them?