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Case reports

The Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR) publishes case reports on current administrative procedures regarding breaches of the Verpackungsgesetz (Packaging Act). The purpose of these reports is to make it easier for companies under obligation to fulfil their ecological producer responsibility and thus to prevent potential legal breaches.

Under the Verpackungsgesetz, the ZSVR is required to inform the parties under obligation and the general public to a relevant and reasonable extent (section 26 (2) no. 7 VerpackG (Packaging Act)). The published case reports constitute such information. The ZSVR calls in particular for all parties under obligation (producers, systems, sector-specific solutions) as well as auditors to take note of these reports.

Specific case reports

Publication date
15 February 2024

Administrative procedure
Disclosure requests or exchange of information pursuant to section 26 (1) no. 20 VerpackG

Facts of the matter
An online shop sold beverages subject to deposit without a deposit label and without charging a deposit.

Duties involved
Deposit obligation and registration requirement

Case report 01/2024: Online shop sells sodas in single-use beverage packaging subject to deposit – without charging deposit

published on 15 February 2024

pdf, 181 KB

Publication date
31 March 2023

Administrative procedure
Information reported to the responsible state authorities because there are specific grounds to suspect that administrative offences have been committed, cf. section 26 (1) no. 21 VerpackG (Packaging Act)

Facts of the matter
Producer failed to file declarations of completeness in breach of statutory duty

Duties involved
Duty to file an audited declaration of completeness pursuant to section 11 VerpackG

Packaging involved
Retail, grouped and shipment packaging subject to system participation

Case report 01/2023: Food producer failed to file declaration of completeness

published on 31 March 2023

pdf, 177 KB

Publication date
30 Otcober 2020

Administrative procedure
Information reported to the responsible state authorities because there are specific grounds to suspect that administrative offences have been committed, cf. section 26 (1) no. 21 VerpackG (Packaging Act)

Facts of the matter
Various affiliated fashion boutiques of an international brand that is located in Germany and sells directly to customers via its own online shop violated statutory packaging law obligations for years

Duties involved
System participation and registration

Packaging involved
Retail, grouped and shipment packaging subject to system participation for textiles, shoes or leather goods

Case report 04/2020: Imports and failure to participate packaging in a system in the case of fashion boutiques with an online shop

published on 30 October 2020

pdf, 103 KB

Publication date
21 September 2020

Administrative procedure
Information reported to the responsible state authorities because there are specific grounds to suspect that administrative offences have been committed, cf. section 26 (1) no. 21 VerpackG (Packaging Act)

Facts of the matter
A large group of affiliated IT firms with a proprietary direct selling organisation failed to comply with its statutory packaging law obligations over many years

Duties involved
System participation and registration

Packaging involved
Retail, grouped and shipment packaging subject to system participation for information technology devices such as screens, keyboards, mice, printers, notebooks, desktop computers, servers, storage units, including hard drives, memory cards and USB flash drives

Case report 03/2020: IT firm fails to meet system participation requirement

published on 21 September 2020

pdf, 101 KB

Publication date
14 April 2020 with changes of 15 April 2020 

Administrative procedure
Hearing of registered experts and other auditors due to gross breach of duty against the declaration of completeness audit guidelines, cf. section 27 (4) VerpackG (Packaging Act)

Facts of the matter
Several registered experts and other auditors ignored evident differences in volumes when auditing and confirming declarations of completeness for the reference year 2018

Duties involved
Obligation to observe the legal requirements and the audit guidelines during audit activities under the Packaging Act

Packaging involved
Packaging subject to system participation that was placed on the market in the reference year 2018

Case report 02/2020: Auditor violation of guidelines - unqualified opinion of declarations of completeness despite significant differences in volumes

published on 14 April 2020 with changes of 15 April 2020

pdf, 137 KB

Publication date
19 March 2020 with changes of 23 April 2020

Administrative procedure
Information reported to the responsible state authorities because there are specific grounds to suspect that administrative offences have been committed, cf. section 26 (1) no. 21 VerpackG (Packaging Act)

Facts of the matter
A German garden centre with several branches and mail order business has breached its obligations under packaging law

Duties involved
System participation and declaration of completeness for the 2018 reference year

Packaging involved
Retail and shipment packaging subject to system participation for garden centre supplies (plants, perennials, plant soil, potting soil, peat, bark mulch and more)

Case report 01/2020: Garden centre - Failure to system participation and lack of a declaration of completeness

published on 19 March 2020 with changes of 23 April 2020

pdf, 143 KB