The registration requirement applies to packaging subject to system participation. The fact that 'used packaging' is being used does not address the issue of whether the packaging has participated in a system. If the packaging at issue is, for example, a carton that was previously transport packaging ('What is transport packaging?') or retail packaging that was used in an industrial or large commercial enterprise setting, it has not been subject to system participation. If this type of used packaging is then placed onto the German market for the first time, for typical use with private final consumers, then its initial distributor must register and participate the used packaging in a waste management system. Only where a distributor has definite evidence that the packaging they are using has already undergone system participation do the registration and system participation requirements fall away.
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