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Packaging Act

What is an initial distributor?

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An initial, or first-time, distributor is a natural or legal person who places packaging or a packaged article on the market in Germany for the first time. This applies both to packaging that is produced in-house and to packaging that is purchased from third parties. The initial distributor is responsible for compliance with the requirements of the German Packaging Act (VerpackG).

Obligations as the first distributor

As a first distributor, you have a number of obligations under the German Packaging Act. These include:

  1. Registration with the Central Packaging Register (ZSVR): initial distributors must register with the ZSVR in order to place their packaging on the market in Germany.
  2. Reporting of packaging quantities: Initial distributors must report their packaging quantities placed on the market to the ZSVR annually. The report must be submitted by May 15 of the following year.
  3. Participation in a dual system: initial distributors must participate in a dual system that is responsible for the disposal of the packaging they place on the market.
  4. Proof of compliance with obligations: Initial distributors must have proof of compliance with their obligations under the Packaging Act and be able to present this to the ZSVR upon request.

Which packaging is affected?

The Packaging Act applies to all packaging that accumulates in private end use and is not disposed of by the commercial end user himself. This includes, for example, packaging of food, cosmetics or electrical appliances. However, packaging intended exclusively for export and repackaged products are excluded. For the purposes of the Packaging Act, private end consumers also include so-called "equivalent waste generation points". These are, for example, gas stations, hospitals, theaters or public authorities.

Non-compliance with the obligations

Non-compliance with the obligations under the Packaging Act can lead to severe fines. In case of missing registration or non-reporting of packaging quantities, fines of up to 200,000 euros may be imposed. Failure to label packaging or to participate in a dual system can also result in fines of up to 100,000 euros.

What is a dual system?

A dual system is a private waste disposal service provider approved by the Central Packaging Register Office (ZSVR) that is responsible for the disposal of packaging. Participation in a dual system is mandatory for initial distributors and serves to ensure proper disposal of packaging.

What are the advantages of complying with the Packaging Act?

By complying with the Packaging Act, you contribute to environmental protection and sustainable packaging disposal. Packaging is recycled and resources are conserved. In addition, fines can be avoided, which are threatened in case of non-compliance with the obligations.

How can you ensure compliance with the Packaging Act?

To ensure compliance with the obligations under the Packaging Act, it is advisable to choose a suitable partner to assist with implementation. This includes, for example, consultants or disposal service providers. Training and seminars can also help to better understand the Packaging Act and to implement the obligations correctly.


As an initial distributor, you are responsible for complying with the German Packaging Act. Proper registration, reporting of packaging quantities, participation in a dual system and labeling of packaging are essential to avoid fines and to contribute to sustainable packaging disposal. It is worthwhile to deal with the requirements of the Packaging Act at an early stage and, if necessary, to take advantage of support during implementation.