General section of the system participation requirement catalogue (only available in German)
About the catalogue
If you are looking for basic information about the system participation requirement catalogue, this page is for you. Under the Verpackungsrecht-Durchführungsgesetz (German Packaging Law Implementation Act – VerpackDG) , packaging subject to system participation includes sales and grouped packaging, primary production packaging, transport packaging – provided that, for the most part, it accumulates as waste with private households or comparable sources of waste generation after use – and service packaging.
Comparable sources of waste generation are defined in section 3 (7) VerpackDG and include restaurants, hotels, hospitals, canteens, amusement parks, libraries and schools. Other examples are craft enterprises (e.g. laundries) and agricultural holdings (e.g. plant nurseries), where packaging waste can be disposed of at the rate that is normally associated with private households and in waste bins that do not exceed 1,100 litres per collection group.
Packaging not subject to system participation includes
packaging for which evidence can be produced that it is not handed over to end users in Germany,
packaging that does not accumulate as waste with private households or comparable sources of waste generation but instead typically accumulates as waste in retail and industrial settings,
reusable packaging,
single-use beverage packaging subject to deposit and
sales packaging for hazardous contents.
Laying the groundwork with an overall market assessment
Whether packaging 'for the most part typically' accumulates as waste with private households or comparable sources of waste generation depends on the result of an overall market assessment. The classification of packaging as being subject to system participation does not hinge on any specific case, sector or distribution channel.
The comprehensive overall market assessment was conducted by GVM Gesellschaft für Verpackungsmarktforschung mbH (GVM). GVM conducted an in-depth analysis of the supply chains for sales and grouped packaging across almost all sectors, as well as for transport packaging (including packaging intended for the shipment of products). While doing this, GVM also identified comparable sources of waste generation. In the case of craft enterprises and agricultural holdings, they also considered the statutory criterion of volume.
Based on the findings, the Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR) issued an administrative regulation for determining the system participation requirement.
The system participation requirement catalogue as an administrative regulation
The VerpackDG entrusts the ZSVR with the statutory duty of determining which packaging must participate with a system (section 54 (1) no. 33 VerpackDG). The ZSVR determines the system participation requirement of a packaging unit upon application by issuing an administrative act.
Its decision is usually based on the system participation requirement catalogue.
The ZSVR has published the system participation requirement catalogue as a norm-interpreting administrative regulation. The catalogue gives an indication of how the ZSVR would likely decide an application concerning the classification of packaging as being subject to system participation or not.
Catalogue structure
General section
The General section will help you use the system participation requirement catalogue as an administrative regulation. It contains relevant definitions and basic explanations to help users better understand and correctly apply the Special section. It also provides information about decisions regarding the system participation requirement of transport packaging.
Please note: search results and product group sheets must always be used together with the General section, never on their own.
Special section
The Special section provides information about decisions regarding the system participation requirement of sales and grouped packaging. As these packaging types are classified taking the packaged product into account, the Special section is organised by product groups and products. The product sheets will be available in English soon.
How the overall market assessment was conducted
In order to determine whether packaging for the most part accumulates as waste with private households or comparable sources of waste generation, the assessment considered factors such as the contents of the packaging (who is the typical consumer/user of the packaged product?) and the design of the packaging, including its size and other properties (e.g. content quantity, material and weight). Typical distribution channels (retail shop or wholesaler) were also taken into account.
These criteria were thoroughly analysed by GVM. GVM then collected further data by evaluating
concrete reference lists of sources of waste generation,
telephone surveys,
store checks,
online product ranges,
distribution data from distributors,
statistics on size categories to delineate the volume criterion for craft enterprises and agricultural holdings.
GVM discussed the results for each product group with the ZSVR during regular evaluations and then reviewed them further with other relevant authorities. This procedure is set to be applied to all future additions or amendments to the catalogue, which will then be released as part of consultation procedures.
The VerpackDG catalogue will be revised if market changes that could affect the result of the overall market assessment are identified for individual product groups.