What packaging subject to system participation?

Recycling box with paper
The German Packaging Act transposes EU Directive 94/62/EC into national law. It regulates how all market players, from manufacturers to retailers to private households, are to deal with packaging to minimize the impact on nature. In addition to preventing pollution, the aim is also to reuse resources more and increase recycling rates. In this article, you will find out what the term "system participation obligation" means and what you must do in concrete terms to meet the legal requirements.
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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.


What counts as packaging subject to system participation?

The following materials are subject to system participation:

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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:

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:

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.

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