Important issues under the amended version of the Verpackungsgesetz as of 1 July 2022:
- Registration of all producers of packaging in the LUCID Packaging Register including information about the types of packaging they place on the German market. The registration requirement will then no longer apply only to companies that place packaging subject to system participation on the German market, but also to those placing packaging not subject to system participation on the market. This includes packaging pursuant to section 15 (1) VerpackG (Packaging Act), such as
- transport packaging;
- retail and grouped packaging that does not typically accumulate as waste with final consumers;
- retail and grouped packaging for which system participation is excluded due to system incompatibility pursuant to section 7 (5);
- retail packaging for hazardous contents packaging;
- reusable packaging; and
- single-use beverage packaging subject to deposit pursuant to section 31.
- Data reporting on packaging volumes is still only due for packaging subject to system participation and must be submitted to the systems and LUCID Packaging Register at the same time interval and with identical content.
- Registration of final distributors of service packaging in the LUCID Packaging Register who have delegated their obligations completely to an upstream distributor. In addition, this delegation must be confirmed by checking the corresponding checkbox in the LUCID Packaging Register.
It is still the case that manufacturers and distributors of service packaging to whom final distributors have delegated the fulfilment of their obligations must register in the LUCID Packaging Register and fulfil further obligations.
- New extended obligations for 'electronic marketplaces/platforms and fulfilment service providers': Operators of electronic marketplaces/platforms may only allow the marketing of packaging subject to system participation if producers have ensured system participation and are registered in the LUCID Packaging Register. Fulfilment service providers may only perform their activities for those companies that have fulfilled their obligation to register with the LUCID Packaging Register and met their system participation requirement.