skip to main content

About the catalogue

If you are looking for essential information about the use of the system participation requirement catalogue, this page is for you. Packaging subject to system participation is retail, grouped or shipment packaging that is filled with goods.

Under the Verpackungsgesetz (Packaging Act), packaging subject to system participation is packaging that typically accumulates as waste with private final consumers after use. A final consumer is someone who does not go on to commercially place the goods on the German market in the form delivered to them. Private final consumers include not only private households, but also comparable sources of waste generation within the meaning of section 3 (11) VerpackG (Packaging Act). These comparable sources of waste generation are not listed exhaustively in the Verpackungsgesetz, examples include restaurants, hotels, hospitals, canteens, amusement parks, garden centres, laundries, libraries and schools. Craft enterprises and agricultural holdings where packaging waste is collected at the rate that is normally associated with private households and in a waste bin that does not exceed 1,100 litres per collection group also count as comparable sources of waste generation.

Retail packaging includes service packaging and shipment packaging. Service packaging is always subject to system participation. Shipment packaging is almost always subject to system participation.

Conversely, packaging not subject to system participation includes export packaging that provably does not accumulate as waste in Germany, large commercial packaging accumulating in industrial contexts (i.e. with non-comparable sources of waste generation), transport packaging, reusable packaging, single-use beverage packaging subject to deposit and retail packaging for hazardous contents.

Laying the groundwork with a generalised market assessment

Whether packaging 'typically’ – i.e. for the most part – accumulates as waste with private final consumers depends on the result of an overall market assessment by product groups, which was conducted in a generalised form by GVM Gesellschaft für Verpackungsmarktforschung mbH (GVM). That means that the classification of packaging does not hinge on any specific case, sector or distribution channel. GVM also considered the criterion of volume for sources of waste generation – something an individual producer is not able to do. They further assessed the concrete supply relationships for the different sectors / products groups, again taking account of the sources of waste generation and their volumes. It is based on the typical source of waste generation in this assessment that the Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR) determines the system participation requirement. The ZSVR then issues administrative regulations on the matter.

Because the initial distributor generally cannot and/or will not undertake an overall market assessment, the Verpackungsgesetz entrusts the ZSVR with the statutory duty of determining which packaging must participate with a system (section 26 (1) VerpackG). The ZSVR determines the system participation requirement of packaging upon application.

The system participation requirement catalogue as an administrative regulation

The ZSVR publishes norm-interpreting administrative regulations. This helps reduce the number of expected classification decisions. It also saves producers within the meaning of section 3 (14) VerpackG ('initial distributors') the time and effort of making case-by-case applications.

These norm-interpreting administrative regulations indicate how the ZSVR would likely decide an application concerning the classification of packaging as being subject to system participation or not. For ease of use, they are published in the form of a system participation requirement catalogue.

This catalogue provides producers or initial distributors with guidelines for classifying packaging in cases of doubt. The system participation requirement is presented clearly and transparently. Under the Verpackungsgesetz, the classification of packaging as being subject to system participation or not must not longer be based on expert opinions. Instead, the catalogue is to be applied for this purpose.

The catalogue is divided into sections to make it easy for users to find a wide range of information.

Learn more about the structure and background of the catalogue, the underlying methodology and its area of application. The guidelines also contain useful information about the catalogue's practical application, for example when dealing with different types of packaging.

Guideline

Overview of the product groups contained in the catalogue.
This file is available in German only.

Catalogue table of contents

How the catalogue was created

The catalogue is based on the ZSVR's interpretation of the term 'typically'. For all of the products, the question was whether packaging waste could typically be deemed to accumulate with private final consumers, bearing in mind prevailing practice. The assessment based on prevailing practice employed objective criteria. These include the contents of the packaging (who is the typical consumer or user of the packaged goods/product?) and the design of the packaging, including its size and other properties (e.g. content quantity, material and weight). Typical distribution channels (retail shop or wholesaler) are also taken into account.

These criteria were thoroughly analysed by GVM. GVM then collected further data through the evaluation of

  • concrete reference lists of sources of waste generation,

  • telephone surveys,

  • store checks,

  • online product ranges,

  • distribution data from distributors and

  • statistics on size categories to delineate the volume criterion for craft enterprises and agricultural holdings.

The methodology behind the system participation requirement catalogue

pdf, 195 KB

GVM discussed the results for each product group with the ZSVR during regular evaluations and then reviewed them further with other relevant authorities. The same procedure applies for later additions or amendments to the catalogue, released as part of consultation procedures.

The ZSVR last updated the system participation requirement catalogue in 2023. A draft version of the catalogue was first published in August 2018 as part of a public consultation to engage industry stakeholders. Following this consultation, the catalogue was published as an administrative regulation that same year.

The catalogue has been reviewed annually since then, amended as necessary and expanded to include missing products. The ZSVR has added one new product group and a total of 79 product sheets during these annual consultations over the past years. A new catalogue, including these additions and amendments, was published accordingly.

The ZSVR again reviewed and edited the catalogue before publishing its 2023 edition, with a total of 25 products and corresponding product sheets being added across nine existing product groups.

Service packaging is always subject to system participation – without exception. This is why they are not listed in the catalogue. Further information can be found in the knowledge base dedicated to service packaging.

Questions

Do you have questions or comments about applying the system participation requirement catalogue?

Please do not hesitate to write to the following e-mail address if you have questions or comments about the catalogue: katalog@verpackungsregister.org

In your e-mail, please provide your full contact details and, if applicable, the complete address of your company or organisation.

We ask for your understanding that

  • inquiries by telephone will not be answered.

  • anonymous inquiries will not be answered.

  • inquiries not accompanied by complete contact details will not be answered.

  • responding to inquiries may take some time.

  • press inquiries sent to the contact address above will not be answered. Please direct these exclusively to presse@verpackungsregister.org.