The system participation requirement applies to packaging that typically accumulates as waste with private final consumers after use. 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 kind of used packaging is then placed on 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 system. Only where distributors have definite evidence that the packaging they are using has already undergone system participation does the system participation requirement fall away.
The party using the used packaging material has to be able to provide evidence of system participation to the competent authorities upon request. As this does not lie within the responsibilities of the Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR), the ZSVR does not set out specific requirements as to this evidence.
Please note that additional packaging components that have not been used, i.e. new elements such as tape, labels or filler material, also have to participate in a system in any case if the packaging is subject to system participation.
It goes without saying that it makes sense from an ecological point of view to re-use packaging material.
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