Overview of packaging types- which are subject to licensing and which are not?
Packaging is an essential part of retail and logistics. It protects goods, facilitates transportation and is often also an important marketing tool. However, not all packaging is the same: depending on its intended use, material and destination, it is subject to different legal requirements. Many companies are particularly concerned with the question of whether packaging is subject to system participation or not. This article provides you with a detailed overview of the different types of packaging and their licensing obligations under the German Packaging Act (VerpackG).
Overview: The Most Important Types of Packaging
Packaging can be categorized based on its purpose and function. The most important types of packaging are:
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Product packaging (direct contact with the product)
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Service packaging (e.g., to-go containers)
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Shipping packaging (protection during shipment)
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Transport packaging (protection in wholesale and logistics)
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Reusable packaging (repackaging for multiple uses)
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Packaging for hazardous contents (special regulations)
Each of these types is subject to different legal regulations. The key question is: Is the packaging subject to system participation or not?
Which Common Packaging Types Are Subject to System Participation?
Packaging subject to system participation must be licensed through a dual system. These include:
Product Packaging
These protect the product directly and are usually provided to the end consumer along with the goods. Examples:
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Cereal boxes
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Wine bottles
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Canned goods
Since they typically end up in household waste, they must be licensed.
Service Packaging
Service packaging is filled at the point of sale and handed directly to customers. These include:
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Coffee-to-go cups
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Pizza boxes
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Bread bags
These are also subject to system participation.
Shipping Packaging
In e-commerce, goods are shipped in boxes or mailer bags. Packaging materials such as bubble wrap or packing peanuts also fall under this category. Since they become waste at the end consumer, they are subject to licensing.
Which Packaging Types Are Not Subject to System Participation?
Packaging not subject to system participation does not end up with private end consumers but remains in commerce or industry.
Transport Packaging
Used to protect goods during transport and stays with wholesalers or producers. Examples:
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Pallets with stretch wrap
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Transport crates
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Shrink wrap for securing loads
These do not require system participation, but companies must ensure proper take-back and disposal.
Reusable Packaging
Designed to be reused multiple times. These include:
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Refillable glass bottles
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Deposit beverage crates
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Reusable containers for takeaway food
Since they do not enter the regular waste stream, they are exempt from system participation.
Export Packaging
Packaging intended exclusively for export and demonstrably not disposed of in Germany is also not subject to system participation.
Licensing Obligation and Legal Requirements
Companies placing packaging subject to system participation on the market must comply with the following regulations:
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Registration in the LUCID Packaging Register: All initial distributors must register with the Central Packaging Register (ZSVR).
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Licensing through a dual system: The packaging volumes must be reported and a corresponding licensing fee must be paid.
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Reporting of packaging volumes: Companies are required to regularly report the quantities of packaging they place on the market.
Frequently Asked Questions
Which types of packaging are subject to system participation?
Product, service, and shipping packaging that becomes waste at the end consumer must be licensed and registered with a dual system.
Which packaging is not system-relevant?
Transport, reusable, and export packaging is not subject to system participation, as it is not typically disposed of by the end consumer.
Which packaging is covered by the Packaging Act?
The Packaging Act regulates the licensing obligation for sales, shipping, and service packaging that becomes waste at the end customer.
Are pallets packaging that is not subject to system participation?
Yes, pallets are considered transport packaging and are not subject to system participation, but they must be taken back and properly disposed of by the distributor.