This selection should be made by anyone who fills empty packaging for the first time with goods and hands it over to final consumers or distributors on a commercial basis in Germany and that packaging typically accumulates as waste with private final consumers. Manufacturers of packaged goods are one example. This selection should also be made by mail order and online retailers that fill shipment packaging with goods and send it.
This selection should also be made by final distributors of service packaging such as bakeries and restaurants or takeaway providers who have not purchased pre-participated service packaging. Additionally, upstream distributors (e.g. suppliers, wholesalers) that have undertaken system participation on behalf of the final distributor should make this selection.
Private final consumers include private households and, because of the nature and quantity of the packaging waste that accumulates there, so-called comparable sources of waste generation such as restaurants and accommodation establishments, commercial kitchens and canteens, as well as offices of freelance professionals, hospitals and educational institutions. Furthermore, this includes craft enterprises and agricultural holdings where their packaging waste is collected at the rate that is normally associated with private households and in a waste bin that does not exceed 1,100 litres per collection group.
More information and examples:
Retail packaging is typically offered to the final consumer as a sales unit consisting of goods and packaging. It is subject to system participation if it typically accumulates as waste with private final consumers after use.
Examples of sales units subject to system participation include:
- 500g tubs of margarine;
- a battery-powered screwdriver in a folding box;
- bag containing 80 clothes pins;
- multi-unit packaging as a sales unit (e.g. 10 coffee capsules in a folding box, 50 chocolate figures like elves or Easter bunnies);
- assortment packaging as a sales unit (e.g. a craft assortment with separately packaged units in a box).
- Grouped packaging contains a certain number of sales units and is typically offered to final consumers with the sales units. It is subject to system participation if it typically accumulates as waste with private final consumers after use.
An example of grouped packaging is a bundle wrap film surrounding 6 x 1.5-litre bottles of mineral water.
Shipment packaging is first filled by the final distributor to enable or facilitate shipping the goods to the final consumer. It is subject to system participation if it typically accumulates as waste with private final consumers after use. Examples of shipment packaging include:
- shipping boxes;
- shipping bags;
- filler material, straps or tape, labels.
Service packaging is filled for the first time by the final distributor to enable or facilitate handing over goods to the final consumer. Service packaging is subject to system participation without exception. Examples of service packaging include:
- packaging such as bakery bags that are filled with baked goods in the bakery;
- packaging such as trays, films, bags or paper bags that are filled with meat or sausage products in the butcher’s shop;
- paper or films used to wrap flowers or plants at the florist;
- plastic, paper and cooler bags that the customer receives and fills with their purchases at the shop;
- packaging that is filled with goods at a market stall;
- packaging such as takeaway coffee cups, bowls for combination meals and chips, pizza boxes or foils that are filled with food or beverages at restaurants, hotels, snack bars and kiosks;
- bags for fruit and vegetables at the supermarket;
- cups for ice cream or milkshakes at ice cream parlours;
- paper bags for fruit and vegetables at direct sellers or farm shops;
- cream jars filled at the chemist, carrier bags, blister packs or paper bags or
- packaging such as bags, textile bags or cases that are filled with goods by opticians or jewellers and given to customers.
Final distributors such as bakeries, restaurants or takeaway providers should make this selection if they purchase all of their packaging exclusively with pre-participation.
Service packaging is considered exclusively pre-participated if an upstream distributor (e.g. suppliers, wholesalers) have undertaken full system participation for the unfilled packaging and indicate accordingly on the invoice and/or delivery note.
Anyone who places service packaging that is exclusively pre-participated as well as other packaging that is subject to system participation on the German market must make the selection above that reads 'Retail, grouped and shipment packaging that typically accumulates as waste with private final consumers'.
There is a possible exception to system participation for service packaging. Pursuant to section 7 (2) VerpackG, a final distributor of service packaging can require an upstream distributor of unfilled service packaging (for example the supplier or wholesaler) to assume responsibility for fulfilling packaging law obligations. If a final distributor exercises this provision, the obligation to undertake system participation for the service packaging is transferred.
Use the system participation requirement catalogue to figure out if your packaging needs to participate with a system or not. The catalogue is a database that allows you to search for products or articles of packaging and determine their system participation requirement status directly for yourself.
This selection should be made by people who place single-use beverage packaging subject to deposit pursuant to section 31 VerpackG, fill it with a beverage for the first time and hand it over to final consumers or distributors on a commercial basis in Germany. This includes beverage manufacturers in particular.
Redistributors such as retailers, takeaways or kiosks that source single-use beverage packaging subject to deposit from wholesalers in Germany are not included here. They purchase single-use beverage packaging that has already been filled.
Importers that bring single-use beverage packaging into Germany should also make this selection.
Single-use beverage packaging is generally subject to deposit, with the exception of the packaging listed in section 31 (4) nos. 1-7 (a)-(j) VerpackG. Single-use beverage packaging subject to deposit must participate in the DPG Deutsche Pfandsystem GmbH deposit system (section 31 (1) VerpackG) and is not subject to system participation (section 12 VerpackG).
Components of single-use beverage packaging subject to deposit that are subject to system participation: Grouped packaging and retail packaging with a bundling function may be subject to system participation, even if the single-use beverage packaging subject to deposit covered itself is not. This includes things like bundle wrap films, trays, cartons and bottle crates/bottle carriers. If that applies to your sales units, you should also make the selection above relating to packaging subject to system participation.
The following single-use beverage packaging is excluded from the deposit requirement because of quantity, design or content:
- single-use beverage packaging with a volume of less than 0.1 and more than 3.0 litres;
- square, gable-top or cylindrical beverage cartons, or tubular bags for beverages made from polyethylene, or foil stand-up pouches;
- single-use beverage packaging with the contents listed in section 31 (4) no. 7 VerpackG, with beverage cans always being subject to deposit regardless of content. The same applies to single-use plastic bottles for beverages with a few exceptions. Further details can be found in the overview 'of the extended deposit obligation for single-use beverage packaging'.
This selection applies particularly to distributors of industrial packaging filled with goods.
Packaging is not subject to system participation if it typically accumulates as waste somewhere other than with private final consumers.
Industrial settings are one of the sources of waste generation where packaging that is not subject to system participation accumulates.
Other examples include craft enterprises and agricultural holdings where their plastic, metal and composite packaging and/or paper/paperboard/cardboard is not collected at the rate that is normally associated with private households and in waste bins that do not exceed 1,100 litres per collection group (not comparable sources of waste generation).
Packaging that does not typically accumulate as waste with private final consumers includes, for example:
- retail and grouped packaging for milk and milk beverages in quantities over 28 litres;
- sacks of malt in quantities of 24 kg delivered to large breweries;
- retail packaging for bricks and tiles for buildings;
- retail packaging for animal feed for farm animals in big bags in quantities of 28 kg;
- retail packaging for coffee in big bags in quantities of 6 kg.
Anyone who places packaging filled with hazardous contents on the German market should make this selection. Hazardous contents are only the substances, compounds and products detailed in Appendix 2 to section 3 (7) VerpackG. Generally this involves:
- substances and mixtures to which the self-service ban under the Chemikalien-Verbotsverordnung (Chemicals Ban Ordinance) would apply;
- agricultural chemicals for professional users;
- certain respiratory sensitising compounds;
- certain oils, liquid fuels and other petrochemical products.
More information and examples:
Retail packaging that can contain hazardous contents is listed in the catalogue of packaging subject to system participation. It deals with hazardous contents in the following way:
- If all individual products in a catalogue sheet are classified as hazardous contents, all of the retail packaging is classified as not being subject to system participation.
- If the individual products in a catalogue sheet are either partially or are very likely to be classified as hazardous goods, then the need to undertake a preliminary investigation is noted in the explanation and/or special features section.
Retail packaging for hazardous contents includes, for example:
- retail packaging for agricultural chemicals for professional users;
- retail packaging for explosives.
This selection applies to people who deliver goods in transport packaging, for example on single-use palettes, to retailers via a forwarding agent or their own freight operators. Transport packaging typically does not accumulate with final consumers and instead remains with retailers. It is therefore not the same as shipment packaging, which typically accumulates as waste with private consumers. Retailers are the sector of the economy that sell the goods onwards in the form in which they were received (e.g., individually) without processing them further.
Transport packaging is often used to bundle multiple sales units into one transport unit. Transport packaging does not include any packaging for sales units (one-piece packaging, multi-piece packaging), even if they also provide protection during transport.
Only single-use transport packaging is included for this purpose. For reusable transport packaging (for example reusable palettes), 'Reusable packaging' should be selected.
More information and examples:
Transport packaging is usually grouped into the terms 'transport boxes, transport films'. A variety of different packaging materials can fall under these terms used in transport packaging:
- folding boxes to bundle multiple sales units into one transport unit;
- shelf-ready boxes that serve only to transport and present the goods;
- shelf trays with or without covering film or intermediate layer;
- display packaging that serves only to transport and present the individual goods (e.g. to display promotional goods);
- intermediate layers in folding boxes, holster boxes or on palettes;
- shrink wrap to bundle multiple sales units into one transport unit;
- single-use palettes.
Transport packaging does not include any packaging for sales units listed as 'retail packaging and grouped packaging' on the relevant product group sheets in the catalogue. That includes, for example:
- bundle wrap films to create a sales unit (e.g. ten .33-litre bottles in a carry pack);
- boxes to create a sales unit (e.g. 240 condensed milk packages in a folding box);
- multi-piece packaging as a sales unit (e.g. 10 coffee capsules in a folding box);
- assortment packaging as a sales unit (e.g. a craft assortment with separately packaged units in a box);
- packaging for sales units of electrical devices, furniture and similar consumer goods (listed in the catalogue under retail packaging because it concerns a sales unit);
- packaging for sales units of installation goods, such as basins, radiators, etc. (listed in the catalogue under retail packaging because it concerns a sales unit).
This selection is not available.
A determination that packaging is incompatible for participation with a system must be issued by the Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR) on a case-by-case basis. No such determination has been issued to date. The issuance of a determination of system incompatibility by the ZSVR is only possible if the uptake of an article of packaging subject to system participation into a system could significantly undermine environmentally-friendly waste management, in particular the performance of proper and safe recovery, or if it could pose a danger to the public good, in particular health.
Anyone who places reusable packaging filled with goods on the German market should make this selection. Pursuant to section 3 (3) VerpackG, reusable packaging is packaging that is intended
- to be used multiple times for the same purpose, and its
- actual return and reuse is facilitated by suitable logistics and
- encouraged by an appropriate incentive system – usually a deposit.
All three of the criteria listed must be met, including a suitable incentive system. Even the fact that an article of packaging can – or is – used multiple times does not make it reusable packaging.
More information and examples:
For packaging to be classified as reusable packaging, the following requirements set out in section 3 (3) VerpackG must be met. Something can only be reusable packaging when arrangements made in advance make it reasonable to believe that it will be used multiple times.
1. Used multiple times for the same purpose
Classification as reusable packaging requires that packaging be suitable for multiple uses for the same purpose.
Later use must be for the same purpose as the first use because anything else might constitute repurposing.
Retail and grouped packaging that can be repurposed after its initial use is NOT exempt from the system participation requirement. Even in such a case, they would eventually, generally after the alternative purpose no longer needs to be served (e.g. as storage packaging), become packaging waste and ultimately need to be recovered by the systems.
Merely designating the packaging for a subjective intended purpose without any measures for its actual reuse is not sufficient. The packaging must be objectively suitable for reuse. That requires that the packaging have a certain sturdiness and be able to be cleaned.
2. Information about return and reuse (adequate logistics)
To be classified as reusable packaging, there must be adequate logistics in place to enable the actual return and reuse of the packaging.
Adequate return infrastructure must exist. Returns must be in fact made possible through return sites for final consumers. In addition, final consumers must be informed about the possibility of returning the packaging. If return options are limited (seasonal, location-based), that tends to suggest that adequate logistics are not in place.
3. Information about the incentive system (deposit)
Another requirement for classification as reusable packaging is an adequate incentive system that supports the return and reuse of the packaging. An incentive system is necessary because it was common in the past for used packaging to circulate less than two times.
A sufficiently high deposit, for example, will generally speaking constitute an adequate incentive system. Incentive systems must be adequate to motivate final consumers to actually return the packaging to the producer.
Using beverage bottles as an example: an adequate incentive system with a deposit of 1 cent is questionable on its face. The typical deposit amount in Germany is 8 or 15 cents. There is no rule that an incentive system must involve a deposit to be adequate; a give-away or price reduction when the packaging is returned would also be an option.
Reusable packaging includes, for example, containers for drinks or food where a deposit is reimbursed for the containers which are then reused, such as:
- plastic cups for hot beverages or
- plastic bowls for takeaway sales of food.