The new Packaging Act

On 01.01.2019, the new Packaging Act (VerpackG) will come into force. The new law replaces the previously applicable Packaging Ordinance. It provides for numerous new obligations for initial distributors of packaging filled with goods that typically accrue as waste at the end consumer. In the event of a violation of the Packaging Act, a fine of up to 200,000 euros can be imposed.
 

This law also affects many print shops and packaging manufacturers, because from January 1, 2019, all print stores that package their products and market them commercially to private end consumers or commercial sources (e.g., administrations, catering businesses, kiosks, or craft businesses) must officially register.
 

Those who fail to do so risk sales bans. In addition, the newly established Central Packaging Register Office (ZSVR) assumes extensive sovereign tasks, such as checking the declaration of completeness.
 

Five steps packaging manufacturers must consider:

1. Check whether your customers are private end users (cf. Section 3 (11) VerpackG) and whether you therefore place sales packaging on the market. In doing so, quantify what proportion of the packaging material is supplied to private and equivalent customers or to large commercial/industrial customers.
2. If the previous point 1 applies in whole or in part, determine the respective total weights of packaging that you place on the market per year, broken down by the various materials, e.g. PPK (paper/cardboard/cardboard), plastics, glass, etc.
3. Register with the Central Office for Packaging Register.
4. Compare system operators, as their contracts vary. Some providers show license fees online, some do not. In any case, you should seek personal contact with the service providers and negotiate an individual offer for your quantities to be licensed. Register with the system operator of your choice and sign a contract for quantities and materials to be licensed. Report your planned quantity to the system operator.
5. Also report the planned quantity reported to the operator to the Central Packaging Register via the Packaging Register. At the latest after the end of the respective calendar year, you must report the packaging quantity actually placed on the market both to the system operator (for final settlement) and via "LUCID" to the Central Packaging Register Office.

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Detailed information on the Packaging Act can be found on the website of the Central Packaging Register Office.