eBay, Amazon – the wealth of online marketplaces that many retailers use as (additional) sales channels is now enormous. But what about the obligation in the context of the German Packaging Act?

Find out what the German Packaging Act means for you in the following practical cases:

You use a fulfilment service provider

  • In fulfilment, the commissioning retailer/manufacturer is responsible for the licensing of shipping packaging.
  • Exception: Who can be identified on the shipping packaging?*

a) only the fulfilment service provider
b) fulfilment service provider AND commissioning retailer OR
c) neither of them
>> In these cases, the fulfilment service provider is responsible for the licensing of shipping packaging.

  • You as  aretailer are only responsible for licensing the product packaging if you fill the product packaging yourself before sending it to your service provider's warehouse.
  •  These guidelines apply the same for retailers and manufacturers based outside of Germany that import their goods to Germany. If you import products from abroad and then sell them to German consumers via marketplaces, you as the importer are usually responsible for all packaging imported into Germany together with the goods. See also The German Packaging Act for Importers.

 

*Important: From July 2022 at the latest, this exception will also be eliminated, so that the commissioning retailer/manufacturer will always be obliged to license the shipping packaging. After the transitional period, the relevant aspects of the amendment to the German Packaging Act from July 2021 will apply. More information on the effects of the amendment for online trade in our blog.

 

You use dropshipping

  • In dropshipping, your service provider (wholesaler/producer) typically fills both the product packaging and the shipping packaging – so you are not responsible for licensing them.
  • If you sell imported products to German consumers via marketplaces, you as the importer are usually responsible for licensing all packaging that together with your products are being imported into Germany. You can find more information on the German Packaging Act for Importers in our blog.

 

You use dropshipping

  • In dropshipping, your service provider (wholesaler/producer) typically fills both the product packaging and the shipping packaging – so you are not responsible for licensing them.

You sell goods from abroad directly to German end consumers

Since you are responsible for the goods when they are shipped directly to the German end user without the involvement of a intermediate retailer when crossing the border, you are responsible for the system participation of the following packaging:

  • all packaging and packaging components that are imported into the German area of application

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