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All you need to know about service packaging

Service packaging can be used in many different places, from pharmacies, amusement parks and flower shops to garden centres, jewellers and opticians, or from market stalls, bakeries and butchers to restaurants, kiosks and snack bars. This knowledge base contains key information about the packaging law obligations associated with service packaging.

Clicking on the service packaging explainer video will start it.


Confused about service packaging and statutory obligations? Watch this explainer video to find out what you need to do.

Service packaging explained

Confused about service packaging and statutory obligations? Watch this explainer video to find out what you need to do.

Clicking on the service packaging explainer video will start it.

Final distributors are companies packaging their goods at the point of sale and directly handing them over to final consumers. Final distributors of service packaging have packaging law obligations to comply with.

What is service packaging?

Service packaging is packaging that is filled at the final distributor's point of sale and that is used to enable or support handing over goods to final consumers.

Heads-up: For packaging to be considered packaging it does not matter

  • whether it is an employee or a customer who fills the packaging.

  • whether customers pay for the service packaging (paper bags, plastic bags, etc.) or that packaging is handed to them free of charge.

  • which material or material combinations the service packaging is made from (paper, plastics, metal, glass, paper composites, plastics composites, etc.).

What defines service packaging?

Whether packaging is service packaging depends on where it is filled:

Filling will also be considered to have taken place on the premises of the final distributor if the packaging was not filled directly at the point of sale. Instead, it can be filled in the nearby vicinity, such as in a separate production or work room adjacent to the sales area. The criterion of 'nearby vicinity' is met if the filling and handing over to final consumers occur at the same premises. It is not met if the filled packaging is transported on a public road between the filling point and the point of sale or the point of handing over to the final consumer. For example, if packaging is filled centrally and then transported to various branches, this would not be within the 'nearby vicinity'. That is to say, the packaging is not considered service packaging.

Heads-up: For packaging to be considered service packaging, it does not matter when it was filled. It may be filled before the actual handover to the customer.

Obligations for service packaging

Service packaging typically accumulates as waste with private final consumers. That is why you must pay for that packaging's recycling. This is called 'system participation'. To comply with your obligations under packaging law, you have two options:

You can either fulfil every obligation yourself:

  1. Register with the LUCID Packaging Register.

  2. Enter into a system participation agreement with a system operator. Please refer to this list for an overview of system operators.

  3. You now have to regularly report your packaging volumes to both your system operator and the LUCID Packaging Register (data reporting).

Or you can buy pre-participated unfilled service packaging:
A special provision applies to service packaging. This allows you to purchase unfilled service packaging from your supplier or wholesaler who has already participated the service packaging with a system for you.

Heads-up: In any case, you have to be registered with the LUCID Packaging Register. If you are exclusively placing pre-participated service packaging on the German market, you have to confirm in your packaging details that you are complying with your packaging law obligations by purchasing pre-participated packaging. If you would like to learn more about that special provision and what you need to enter in the LUCID Packaging Register, check out our dedicated knowledge base.

 

Go to knowledge base

For service packaging, the name you enter as a brand name depends on your circumstances: If you are fulfilling the system participation requirement yourself, enter your company name under 'brand name'. If you are purchasing pre-participated unfilled service packaging, enter your packaging supplier's name.

What packaging is not considered service packaging?

Examples of packaging that is not considered service packaging include the following:

  • Reusable packaging that is part of a reuse scheme

  • Packaging companies use to deliver goods to customers themselves or via a commercial delivery service (shipment packaging)

  • Pre-packaged goods sourced directly from the manufacturer or via a wholesaler (retail packaging)

Reusable cool bags or thermal boxes that serve to transport goods, but are not handed over to customers, are not considered packaging.

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If you need more information so you can take care of all your obligations yourself, you will find everything you need to know here:

Registration

Every company that distributes packaged good commercially on the German market or imports packaged goods into Germany has to register with the LUCID Packaging Register, regardless of where in the world that company is based.

System participation & data reporting

The following obligations apply to packaging subject to system participation: you will need to register with the LUCID Packaging Register, conclude a system participation agreement and regularly report packaging volumes (data reporting).

Packaging types and categories

System participation – yes or no? What types of packaging are there? What are the obligations that come with each of them?

Please refer to the support contact page for more information.

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