Who is a producer and what does that mean?

… the manufacturer who produces, packages and then distributes a product.

… retail companies distributing own brands that are produced, packaged and delivered to them by a third party on their behalf.

• If only the name and/or brand of the retail company is visible on the packaging, that retail company is the party under obligation.

• If the name of the contract packager appears, e.g. with the phrase 'manufactured for [name / brand of retail company]', that contract packager is the party under obligation.

… importers if they bear legal responsibility for the packaged goods at the time these packaged goods cross the border into Germany.

… mail order companies and online retailers that fill shipment packaging with goods for the first time and send them to their customers.

… companies that distribute their goods in service packaging. This is packaging that is either

• filled with goods by the business providing it at the point of sale so that these goods can be handed over to customers (e.g. a sandwich bag or a pastry carrier at a bakery), or

• filled with goods by customers at the point of sale (e.g. takeaway coffee cups or salad bowls in a supermarket).

Please note: Fulfilment service providers and drop shippers are not producers under the Verpackungsgesetz (Packaging Act). However, both must check whether their ordering parties or contractual counterparties fulfil their packaging law obligations.