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System participation confirmation according to VerpackG in online trade

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Since the amendment of the Packaging Act, operators of electronic marketplaces and fulfillment service providers have been obliged to verify the system participation of their retailers. Online retailers who sell their goods via electronic marketplaces require, for example, a so-called system participation confirmation as proof.

Why are online retailers subject to the system participation requirement?

Just like manufacturers of goods, online retailers are also subject to the system participation obligation under the German Packaging Act (VerpackG). The reason for this is that their packaging accumulates as waste after use by consumers and must be disposed of via the Yellow Bin/Yellow Sack, the Blue Bin or public glass containers.

To fulfill their system participation obligation, online retailers must participate their packaging with a dual system. The dual system organizes the disposal process on behalf of manufacturers and online retailers, i.e. collection by disposal companies as well as sorting and recycling of the packaging waste generated.

Following the packaging licensing, each manufacturer and retailer receives a license quantity confirmation from the participating dual system. This serves as proof that the legal obligation has been fulfilled. It lists the licensed material quantities and the dual system involved.

But what is a system participation confirmation?

No marketplace participation without system participation confirmation

From July 1, 2022, online traders who sell goods via an electronic marketplace must be in mandatory possession of a system participation confirmation. Unlike the license quantity confirmation, this does not contain the quantities involved, but still confirms compliance with the legal obligations.

Both for trading via an electronic marketplace such as Amazon or eBay, for example, and for using fulfillment services, online retailers need the system participation confirmation. This is because the operators of electronic marketplaces and fulfillment service providers are obliged to obtain proof and thus to check the system participation of their merchants.

If the proof is not provided, the online retailer is not allowed to sell goods in Germany and marketplace operators and fulfillment partners are not allowed to offer any of their services or carry them out on behalf of the retailer.

License packaging and receive system participation confirmation!

If you operate as an online retailer and only circulate small quantities of packaging materials, you can license them via zmart. By doing so, you participate in the Dual System Zentek. In just a few steps, you have entered your material quantities via our calculator and can conclude the packaging licensing in a legally secure manner.

As a special service, we offer our new customers immediate provision of the system participation confirmation after conclusion of the contract. This also includes confirmation of your EPR number, i.e. the registration number you have received from the Central Packaging Register. This number is a component of the EPR number query. In this case for packaging licensing in Germany.

Conclusion: Sale of goods only with fulfillment of the system participation obligation

As a result of the amendment to the Packaging Act, which came into force on July 3, 2021, stricter regulations apply to online retailers as well as operators of electronic marketplaces and fulfillment service providers. The latter must monitor the system participation of retailers operating through them. Otherwise, no goods may be sold in Germany.

To enable online retailers to prove that they comply with their system participation obligation, they receive a system participation confirmation from their participating dual system. This is sufficient to provide marketplace operators and fulfillment service providers with proof.

If you have any questions about your obligations as an online retailer, please feel free to contact our customer service. We can answer any questions you may have about their system participation, packaging licensing and the sale of goods via electronic marketplaces.

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