Amendment of the German Packaging Act: Distributors of transport packaging are also affected


With the amendment of the German Packaging Act coming into effect on 3 July 2021, a number of things have changed for merchants and producers. Online trade in particular is affected by the new requirements. But the amendment also brings changes for distributors of transport packaging that must be considered. In the following article we inform you in detail about the changes.   

Transport packaging includes packaging that is used to transport goods between different traders, such as transport boxes, wooden pallets, barrels or canisters. Transport packaging is mainly used in the business-to-business sector. So unlike sales packaging, it is not usually used for selling products to private end consumers. Transport packaging is therefore considered packaging not subject to system participation under the German Packaging Act. This means that it does not have to be licensed with a dual system like sales packaging.

Although no system participation obligation applies for transport packaging according to the German Packaging Act, it is nevertheless necessary for distributors of transport packaging to comply with certain requirements. Since the Packaging Ordinance – the predecessor of the German Packaging Act enacted in 1991 – there has been a take-back and recycling obligation for distributors of transport packaging. Now the amendment to the German Packaging Act has further tightened the requirements for placing transport packaging on the market beyond the previously existing obligations.

Download overview of the changes in the amendment

What do distributors of transport packaging have to consider in regard to the amendment of the German Packaging Act?

1. Obligation to inform for the final distributor of transport packaging

Since the amendment came into force on 3 July 2021, there has been an obligation to provide information for the final distributors of transport packaging. This means that consumers must be informed extensively by the final distributors of transport packaging about the return options for transport packaging and their purpose.
It is not explicitly defined how exactly the information obligation has to be fulfilled. This means that signs, boards, delivery notes, etc. can be used to provide the information.

2. New requirements in relation to information, proof and documentation

In general the following applies: companies must take back transport packaging and ensure that it is recycled properly (e.g. with support by the environmental service provider Interseroh). The basic idea of this so-called producer responsibility has existed since the beginning of the Packaging Ordinance in 1991.

Due to the stricter requirements of the amendment to the German Packaging Act, the obligation to take back and recycle transport packaging is now supplemented by an obligation to provide proof. This means that from 1 January 2022, companies must provide evidence that they have met their take-back and recycling requirements. The proof must be submitted to the competent state authorities if requested.

3. Obligation to register for packaging not subject to system participation

As part of the amendment to the German Packaging Act, an extended obligation to register has been introduced for distributors of all packaging. This extended registration obligation also affects distributors of transport packaging that is not subject to system participation. After a one-year transitional period, producers must therefore register with the Central Agency Packaging Register in LUCID from 1 July 2022 before they put transport packaging into circulation.

If business owners place packaging that is subject to system participation on the market and are therefore already registered in the LUCID register, they must carry out a further registration with the ZSVR in order to show their activity in relation to transport packaging (or other packaging not subject to system participation).


Interzero is your experienced service provider for the take-back and recycling of transport packaging

First-time distributors of transport packaging can commission a service provider such as Interzero to fulfil their take-back and recovery obligations. As an experienced environmental service provider, Interzero reliably supports its customers in comprehensively meeting the basic as well as all new requirements, thus ensuring sustainable and reliable transport packaging recycling.
As the market leader for the nationwide take-back of  transport packaging and through a nationwide network of disposal partners, Interzero enables simple take-back and efficient recycling of transport packaging. This means that you, as an Interzero customer, hardly have to make any effort to fulfil your transport packaging obligations within the scope of the VerpackG and benefit from cost-efficient offers.

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Conclusion: Stricter requirements for an efficient circular economy

The new requirements of the German Packaging Act amendment affect not only distributors of sales packaging subject to system participation, but also distributors of packaging not subject to system participation (such as transport packaging). Since packaging recycling is an important factor in achieving climate protection goals, the amendment aims to strengthen product responsibility for all types of packaging placed on the market and thus ensure that the use of all packaging is more considerate in the future. The comprehensive regulations are thus an important step towards an efficient circular economy and a more sustainable future.

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