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25. November 2022

Comparison of the obligations under the German Packaging Act

What is the system participation obligation? The designation “packaging subject to system participation” is appearing in an ever increasing number of texts in connection with the German Packaging Act, LUCID registration and the declaration of completeness. In the following article, we would like to shed some light on the subject and clear up any confusion.

Since 1 July 2022, all producers of packed products who bring them into the German market have been obliged to register in the LUCID public register. Under which specific packaging categories does a company have to register its packaging in LUCID? What licensing options are available for the various packaging materials? 

For manufacturers of packed products brought into the German market, Sections 7 and 15 of the Packaging Act determine whether or not packaging must be licensed with a dual system. Packaging to be licensed in a dual system for household packaging is “subject to system participation”. Packaging that is emptied by an industrial or commercial end-user is “subject to non-system participation”. 

In the case of packaging for products for private end consumers that is subject to system participation, the obligation to register with the Central Agency Packaging Register (ZSVR) according to Section 9 of the Packaging Act and the obligation to participate in a dual system according to Section 7 of the Packaging Act shall apply. The additional data reporting obligation and the obligation to submit a declaration of completeness are intended to ensure disposal or recycling by the private end consumer after use.  

In the case of packaging generated by industrial/commercial end consumers, the obligation to register with the Central Agency Packaging Register according to Section 9 of the Packaging Act applies in addition to the obligation for the recovery, recycling, information and documentation of packaging. The latter obligation stipulates that, according to Section 15 of the Packaging Act, disposal/recycling of packaging after use must also be ensured for packaging that is not subject to system participation. Thanks to its take-back systems for commercial packaging, such as RIGK-SYSTEM or RIGK-G-SYSTEM, RIGK assumes the recovery and recycling obligation on behalf of the fillers/distributors as a commissioned third party according to Section 35 of the Packaging Act.  

RIGK is pleased to provide you with a clear overview of the respective obligations.  

Here you will find more explanations and delimitations on this topic, such as the difference between “packaging subject to system participation” and “packaging not subject to system participation”. 

More informationen: 
Claudia Hoese
Customer Relationship Manager / Public Relations Manager
Phone: +49 611 308600-12