For an answer to the question, please see the following excerpt from our FAQ page.
The registration requirement applies to any party who is the first to place retail or grouped packaging filled with goods that typically accumulates as waste with private final consumers after use (referred to as 'packaging subject to system participation' in the Verpackungsgesetz) onto the German market on a commercial basis (referred to as 'producers' in the Verpackungsgesetz).
A 'producer' required to register is therefore:
any party who fills and places onto the German market for the first time empty packaging that typically accumulates with private final consumers (initial distributor);
- any party who imports packaged goods into Germany that typically accumulate with private final consumers, and places them here onto the market for the first time (importer); this can be
any party located abroad that ships the goods to Germany;
- any party located in Germany that orders the delivery.
As a general rule: the party who bears legal responsibility for the goods at the time they cross the border is the 'importer'.
any party in the mail order business sector who fills and places onto the German market for the first time shipment packaging that typically accumulates with private final consumers (mail order companies or businesses or online retailers);
in the case of service packaging, the final distributor of this packaging can also request, as an exception, that the manufacturer / initial distributor of the empty packaging bears the registration requirement.
A manufacturer is not deemed a 'producer' and thus not required to register if they produce packaging and place it onto the German market as empty packaging.