Are you the first to fill this packaging with goods?

If you are the first to place packaging filled with goods on the German market on a commercial basis, you are considered to be a 'producer' under the Verpackungsgesetz (Packaging Act). 

Producers can be…

... manufacturers producing, packaging and distributing a product.

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

... 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 filling shipment packaging with goods for the first time and sending them to their customers.

... companies distributing their goods in service packaging such as takeaway coffee cups or bakery bags.