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Can an upstream distributor of service packaging to whom the system participation requirement has been shifted pass on the system participation requirement?

No, that is not possible. The possibility to pass on the system participation requirement serves to reduce the burden especially for small and medium-sized artisanal food production businesses. In the case of service packaging, they are able to shift the system participation requirement and require an upstream distributor (for example the supplier of such packaging) to undertake system participation. However, that party in turn does not have a right to shift the requirement onward.