What does system participation obligation mean and what measures do you have to take?
Packaging that is subject to system participation is material that is disposed as waste by the end consumer. This includes, for example, product packaging as a shampoo bottle, service packaging such as coffee-to-go cups and outer packaging holding together several products for means of transportation. These materials must be fed into a dual system so that they can be recycled. This circumstance is expressed by the term “system participation obligation”.
If you, as the end consumer in Germany, have received such packaging material as part of a product purchase, you must separate and dispose of it properly.
Dealers, manufacturers and distributors whose product or shipping packaging is subject to the system participation obligation must register with the LUCID packaging register as well as a dual take-back scheme. From July 1, 2022, the registration obligation will also apply to transport packaging which is only intended for use between manufacturer and retail and is not received by the end consumer. Not participation at a dual take-back scheme is needed in this case. For packaging delivered to a private end consumer or an equivalent point(shops, garages, hospitals, school, restaurants etc.), you must conclude a contract with a dual system that is responsible for the proper disposal and recycling of the materials Last but not least, it is your responsibility toreport the sold amounts both to LUCID and the dual system.
LOREM
What counts as packaging subject to system participation?
The following materials are subject to system participation:
- Sales packaging such as film and foil that surrounds wrapped goods, for example DVDs
- outer packaging, for example bottle containers (six packs)
- Service packaging, for example disposable tableware for takeaway meals
- Shipping packaging such as cartons, bubble wrap and shipping envelopes
- Exported materials are also subject to declaration, but can later be declared as exports on the basis of the quantity declarations and therefore deducted in the aftermath
What does not count as packaging subject to the system participation obligation?
The following packaging materials do not fall under the requirements of the system participation obligation:
- Transport packaging such as pallets and displays
- Reusable packaging, such as beverage crates
- Disposable beverage packaging on which a deposit must be charged (DPG)
- Sales and outer packaging that is generated as waste in places other than private households, such as beer kegs
- Sales packaging that contains goods containing hazardous substances, such as fuels, oils, or paints and varnishes
- Large-scale commercial packaging materials or those that remain with industrial companies
Packaging materials that are permanently attached to the goods, i.e. without which the product could not be used, are also not subject to system participation. These include, for example:
- Tea bags
- CD spindles, which are intended for storage of data carriers
- Water-soluble foil bags containing detergents or dishwashing liquids
- Coffee pods and capsules
How can I identify packaging that is subject to system participation?
The following main criteria will tell you whether packaging must be submitted to the dual systems and whether you are therefore required to participate in the system: The hollow material is filled with goods that are intended for the end consumer. Please note that not only private households are considered as end consumers, but also hotels, barracks, craft enterprises, administrations and other organizations.
CERTIFY will be happy to help you answer all your questions regarding the obligation to participate in the system, transport packaging, dual system, LUCID registration, quantity reporting or other issues. With our many years of experience, we are specialists in this field and can thus support you in fulfilling your obligations quickly and cost-effectively.
