Transport packaging: What regulations apply and what must be adhered to?

What Are Transport Packaging Materials?

Transport packaging refers to packaging specifically used for transporting goods between manufacturers, wholesalers, and retailers. Unlike sales packaging, it does not reach the end consumer but remains within the supply chain. Its purpose is to protect goods from damage, weather conditions, and contamination.

Examples of Transport Packaging

Typical examples of transport packaging include:

• Wooden pallets (e.g., Euro pallets) – for heavy or large goods

• Large boxes and crates made of wood or plastic – for machines or delicate products

• Drums and canisters made of metal or plastic – for liquids or chemicals

• Protective films and stretch wraps – for stabilizing pallet loads

• Sacks and foam trays – for bulk goods or sensitive items

These packaging types enable safe transport and facilitate handling for logistics companies and retailers.

Transport Packaging Regulations Under the Packaging Act

Since the Packaging Act (VerpackG) came into force in 2019, transport packaging is subject to regulations requiring companies to take back and dispose of it in an environmentally friendly way.

Who Is Obligated to Take Back Transport Packaging?

According to § 15 VerpackG, manufacturers and distributors must take back transport packaging and ensure its proper recycling. The cost of disposal is borne by the manufacturer or distributor, not by the recipient of the goods.

Proof Obligation Since 2022

As of January 1, 2022, companies placing transport packaging on the market are subject to a documentation obligation. They must prove that they take back and properly recycle the packaging.

Registration Requirement with the Central Packaging Register (ZSVR)

Since July 1, 2022, all companies placing transport packaging on the market must register with the LUCID Packaging Register. This ensures transparency and oversight by authorities.

Difference Between Licensed Sales Packaging and Transport Packaging

The key difference between sales packaging and transport packaging lies in the licensing obligation:

• Sales packaging delivered to end consumers must be licensed and registered in a dual system.

• Transport packaging, used only in B2B contexts, does not require system participation. However, it must be taken back and recycled. Companies must “fulfill their obligations” by documenting proper take-back and disposal but do not need to participate in a dual system.

Disposal and Recycling of Transport Packaging

Environmentally responsible disposal of transport packaging is a core requirement of the Packaging Act. The principle is: Recycling before energy recovery.

Recycling Rates for Transport Packaging

According to the law, certain materials must be prioritized for recycling. The current recycling targets (as of 2022) are:

• Paper, cardboard – 90%

• Glass – 90%

• Metals (aluminum, tinplate) – 90%

• Plastic packaging – 63%

• Composite materials – 70%

These requirements are designed to ensure that transport packaging remains sustainably within the material cycle.

How Can Companies Optimize Disposal?

Companies have several options to fulfill their disposal obligations:

• Independent take-back – companies collect packaging from customers and organize recycling themselves.

• Contracting external waste management providers – specialized services handle collection, sorting, and recycling.

• Using reusable packaging systems – companies rely on returnable transport packaging to minimize waste.

Purchasing and Using Sustainable Transport Packaging

Companies that regularly require large amounts of packaging materials should rely on sustainable alternatives, such as:

• Reusable pallets and crates for multiple uses

• Recyclable materials like corrugated cardboard or bio-based plastics

• Efficient packaging designs to reduce material use

Compliant Use and Disposal of Transport Packaging

Compliance with transport packaging regulations is essential for companies to meet legal requirements and operate more sustainably. Manufacturers and distributors must dispose of their packaging properly, register with the LUCID system, and meet recycling targets.

By working with experts like Zmart, companies can optimize their packaging strategy and licensing, reduce costs, and protect the environment. Choose sustainable packaging solutions to remain competitive in the long term!