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Having packaging classed as being subject to system participation (section 26 (1) no. 23 VerpackG): the application procedure

This page contains important information about how to submit an application.

In order to prepare for the large number of expected classification decisions and to save producers within the meaning of section 3 (14) VerpackG (Packaging Act) ('initial distributors') the time and effort of having to make case-by-case applications, the Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR) has decided to publish norm-interpreting administrative regulations. These contain indications of how the ZSVR would likely decide an application concerning the classification of packaging as being subject to system participation. For ease of use, the administrative regulations are published in the form of a system participation requirement catalogue.

What you need to know

  • Do not send test items that have been used.

  • All decisions are made on a case-by-case basis. General obligations under the Verpackungsgesetz cannot be clarified by the ZSVR, including

    • whether a producer is required to register,

    • the extent of a producer's system participation requirement, and

    • whether a producer is required to submit data reports.

  • Only individual, specific test items (packaging containing goods) are assessed, meaning no

    • product portfolios,

    • goods/product groups or

    • delivery lists.

  • Packaging material alone (without goods) is not an acceptable test item and will not be assessed if sent unfilled, meaning no

    • cardboard boxes,

    • films or

    • labels.

  • Goods alone (without packaging) are also not acceptable test items, meaning no

    • raw materials (e.g. malt, aluminium),

    • products (e.g. hair dryer, garden sheers) or

    • goods (e.g. contact lens solution, gelatine).

  • The ZSVR does not issue any other legally binding determinations beyond what is provided for by law, that means neither

    • individual or general material classifications apart from the classification of hazardous contents or

    • classifications regarding how recyclable an article of packaging or material is.

  • The ZSVR does not make any decisions about labelling, meaning no

    • food law labelling on packaging,

    • packaging law labelling on packaging or

    • any other text on packaging.

Application form for having packaging classed as being subject to system participation

Section 26 (1) no. 23 VerpackG (only available in German)

pdf, 161 KB