Packaging types and obligations – at a glance

Retail packaging is typically offered to private final consumers as a sales unit comprising goods and packaging. Service packaging and shipment packaging are also retail packaging. Here are some examples of sales units with packaging that is subject to system participation:

• 500g tub of margarine

• Battery-powered screwdriver in a folding box

• Bag containing 80 clothes pins

• Multi-piece packaging as a sales unit (e.g. 10 coffee capsules in a folding box, 50 chocolate figures like Santas or Easter Bunnies)

• Assortment packaging as a sales unit (e.g. a craft assortment with separately packaged units in a box)

You can find more examples of retail and shipment packaging in this knowledge base.

Grouped packaging covers one or more retail units. It serves to bundle multiple packaging units and can be used for stocking retail shelves. Here are some examples of grouped packaging:

• Bundle film wrapped around a pack of six 1.5 litre water bottles

• Bundle film wrapped around a pack of three deodorants

• Bundle film wrapped around a two pack of shower gel

• Cardboard box with a six pack of beer

Shipment packaging facilitates the shipment of goods to private final consumers. Mail order companies and online retailers use shipping boxes, bags, envelopes and other packaging to send their goods to customers.

Heads-up: Packaging components like labels, tape or filler material (e.g. bubble wrap, loose fill peanuts) are also considered part of shipment packaging.

Special provision for service packaging: Companies exclusively using service packaging to hand over their goods can purchase pre-participated unfilled packaging from a supplier or wholesaler who has already paid for the packaging's recycling. This must be stated on the invoice and/or delivery note. This option is limited to service packaging only.

Special provisions for service packaging

Single-use beverage packaging is generally subject to deposit. Unlike reusable packaging, single-use beverage packaging is not designed and intended to be used multiple times for the same purpose. Single-use beverage packaging subject to deposit is packaging for liquid foodstuffs that i) is mostly or fully closed and ii) is not reusable. Examples include single-use plastic beverage bottles and beverage cans in quantities between 0.1 to 3 litres filled with

• milk and dairy drinks with at least 50 percent milk content

• sparkling wines and sparkling wine cocktails

• wine and wine-based cocktails

• alcohol products and mixed beverages containing alcohol

• fruit and vegetable juices

Single-use beverage packaging subject to deposit must be participated with the deposit scheme of Deutsche Pfandsystem GmbH (DPG). They are not, however, subject to system participation.

Heads-up: Grouped packaging for single-use beverage packaging can be subject to system participation. This includes films for bundling beverage bottles, trays, cartons and bottle crates / bottle carriers. The system participation requirement does not apply to packaging aids for closing single-use beverage packaging subject to deposit, such as screw caps, lids and crown caps. It also does not apply to labels for single-use beverage packaging subject to deposit. They are considered to be part of the beverage packaging.

Check out our knowledge base on single-use beverage packaging subject to deposit to learn more about the exceptions and obligations.

Unlike shipment packaging, transport packaging does not accumulate with final consumers. It remains with retailers instead. Transport packaging is often used to bundle multiple sales units into one transport unit. It serves to facilitate the transportation of goods between individual distributors and to prevent damage during transit.

Transport packaging does not include any packaging for sales units (one-piece packaging, multi-piece packaging), even if this also provides protection during transportation.

Examples of transport packaging:

• Folding boxes to combine multiple sales units into one transport unit

• Shelf-ready boxes that serve just to transport and present the goods

• Shelf trays with or without covering film or intermediate layer

• Display packaging that serves only to transport and present the individual goods (e.g. to display promotional goods)

• Intermediate layers in folding boxes, holster boxes or on palettes

• Single-use palettes

• Shrink wrap to bundle multiple sales units into one transport unit

• Shrink hood on palettes

• Stretch films for palette loading safety

• Straps

Reusable packaging is packaging

• that is intended to be used multiple times for the same purpose, and

• whose actual return and reuse is facilitated by suitable logistics and

• encouraged by an appropriate incentive system, usually a sufficiently high deposit.

For packaging to be considered reusable, it must meet all three of these characteristics. Even the fact that an article of packaging can – or is – used multiple times does not make it reusable packaging. Packaging can only be classified as reusable if there are prior arrangements suggesting that it will be used multiple times. The incentive systems must be adequate to motivate final consumers to actually return the packaging to the producer.

Examples of reusable packaging include containers for food and beverages that come with a deposit refund for their return and will be reused, such as:

• Beverage bottles for beverages of all kinds

• Yoghurt jars filled with dairy or other products

• Plastic trays or bowls for takeaway sales of food such as fruit or salads

• Plastic cups for hot beverages, for example as used at funfairs or Christmas markets

This packaging does not typically accumulate as waste with private final consumers. Instead, it accumulates with other sources of waste generation such as craft enterprises, agricultural holdings or in industrial or other settings. The decisive factor is that it accumulates with a source of waste generation where plastics, metal and composite packaging and/or paper/paperboard/cardboard can be collected at the rate that is normally associated with private households and in waste bins that do not exceed 1,100 litres per collection group.

Examples of packaging that does not typically accumulate as waste with private final consumers include:

• Retail or grouped packaging for milk and milk drinks in quantities exceeding 28 litres

• Retail packaging for coffee in big bags in quantities exceeding 6 kg

• Retail packaging such as sacks of malt in quantities of 24 kg delivered to large breweries

• Retail packaging such as barrels of honey in quantities exceeding 18 kg

• Retail packaging for bricks and tiles for buildings

• Retail packaging for animal feed for farm animals in big bags in quantities exceeding 28 kg

• Retail packaging such as cans, bottles, canisters and barrels containing lubricating oils in quantities exceeding 0.8 l

Hazardous contents are only the substances, mixtures and products detailed in Appendix 2 to section 3 (7) VerpackG (Packaging Act). This mainly involves the following:

• Substances and mixtures to which the self-service ban under the Chemikalien-Verbotsverordnung (Banned Chemicals Ordinance) would apply

• Agricultural chemicals for professional users

• Certain respiratory sensitising mixtures

• Certain oils, liquid fuels and other petrochemical products