GreenDot supports you in fulfilling your obligations under the Packaging Act (VerpackG). We would be happy to explain what your obligations are and how we can provide you with specific support.
Unlike shipping packaging, transport packaging (TP) does not typically end up with end consumers, but remains in the retail sector. It is often used to bundle several sales units into one transport unit. In this context, it serves to enable the transport of goods and prevent transport damage. In principle, transport packaging (TP), like commercial packaging, is not subject to mandatory participation in a recycling system. Nevertheless, the Packaging Act (VerpackG) stipulates essential manufacturer obligations for this type of packaging.
The Central Agency Packaging Register (ZSVR) was introduced by the Packaging Act (VerpackG). Its purpose is to verify compliance with the provisions of the Packaging Act. Manufacturers who place transport packaging on the market within the meaning of the Packaging Act (VerpackG) must do the following:
Register or extend existing registration in the LUCID register of the Central Agency Packaging Register (ZSVR).
For initial registration, provide contact details, packaging types and brand names.
For extension of existing registration, provide additional packaging types, e.g. transport packaging and brand names.
Manufacturers must indicate the obligation to take back, free of charge, used, completely empty packaging of the same type, shape and size as that placed on the market at the place of actual delivery or in its immediate vicinity.
Due to extended verification and documentation requirements, manufacturers must prepare verifiable internal documentation by 15th May each year detailing the packaging placed on the market, taken back and recycled in the previous year, broken down by material fraction.
Transport packaging is packaging that facilitates the handling and transport of goods in such a way that direct contact and transport damage are avoided. This packaging is typically not intended for distribution to end consumers (Section 3 (1) No. 3 VerpackG). It is therefore not collected via the yellow bin, yellow bag or municipal waste paper collection, but accumulates in shops. The VerpackG does not recognise de minimis limits: those affected must therefore take action from the moment the first packaging is placed on the market and ensure that they fulfil their legal obligations.
Disposable beverage containers are generally subject to a deposit. Unlike reusable containers, these are not designed or intended to be reused multiple times for the same purpose after use. Disposable beverage containers subject to a deposit are closed or predominantly closed containers for liquid foodstuffs that are not reusable containers. Examples include disposable plastic beverage bottles and beverage cans with a filling volume of 0.1 to 3 litres, which are filled with, among other things
milk and milk-based beverages with a milk content of at least 50 per cent,
sparkling wine and sparkling wine-based beverages,
wine and wine-based beverages,
alcoholic products and other alcoholic mixed drinks,
fruit juices and vegetable juices.
Disposable beverage containers subject to deposit must be included in the deposit system of Deutsche Pfandsystem GmbH (DPG). These are generally not subject to system participation.
Please note: Outer packaging of disposable beverage containers may also be subject to system participation. This includes films for bundling beverage bottles, trays, cartons and beverage crates/bottle carriers. Packaging aids used to seal disposable beverage packaging subject to deposit, such as screw caps, lids and crown caps, as well as labels on disposable beverage packaging subject to deposit, are exempt from the obligation to participate in the system. These are considered components of the beverage packaging.
Unlike shipping packaging, transport packaging is not typically returned to end consumers, but remains in the retail sector. It is often used to bundle several sales units into one transport unit. In this context, it serves to facilitate the transport of goods and prevent damage during transport.
Examples of transport packaging:
Folding boxes for bundling several sales units into one transport unit.
Shelf cartons used solely for the transport and presentation of goods.
Open half-cartons with or without cover film or intermediate layer.
Display packaging used solely for the transport and presentation of individual goods (e.g. for the presentation of promotional goods).
Interlayers in folding boxes, half-cartons or on pallets
Disposable pallets
Shrink film for bundling sales units into a transport unit
Shrink hoods on pallets
Stretch film for securing loads on pallets
Strapping bands
Transport packaging does not include any packaging of sales units (single-piece packaging, multi-piece packaging), even if this also serves to protect the goods during transport.
Reusable packaging is packaging that is designed and intended to
be reused multiple times for the same purpose after use and
whose actual return and reuse is made possible by adequate logistics and
promoted by appropriate incentive systems, usually through a sufficiently high deposit.
All three of the above characteristics must be present for packaging to be classified as reusable. The mere fact that packaging can be used multiple times or is used multiple times does not make it reusable packaging. Packaging is only considered reusable if, based on arrangements made in advance, it can be assumed that it will actually be used multiple times. The incentive systems used must be suitable for motivating the end consumer to actually return the packaging to the manufacturer.
Reusable packaging includes, for example, containers for beverages or food that are taken back and reused in exchange for a deposit refund, such as:
Beverage bottles for all types of beverages
Yoghurt pots, for example filled with dairy products
Plastic trays for the takeaway sale of food, for example for salads or fruit
Plastic cups for hot drinks, for example used at fairs or Christmas markets
This packaging does not typically originate from private end consumers, but from other sources, such as industrial companies. This may also include craft businesses and agricultural enterprises if their plastic, metal and composite packaging or paper/cardboard/cardboard packaging cannot be collected at the typical household collection frequency with a maximum 1,100-litre transfer container.
Examples of packaging that is not typically generated as waste by private end consumers after use:
Sales packaging and outer packaging for milk and milk drinks with a filling size of more than 28 litres
Sales packaging for coffee in big bags with a filling size greater than 6 kilograms
Sales packaging such as sacks of malt with a filling size of 24 kilograms, which are delivered to large breweries
Sales packaging such as barrels of honey with a filling size greater than 18 kilograms
Sales packaging for bricks and building blocks for buildings
Sales packaging for feed for farm animals in big bags with a filling size of more than 28 kilograms
Sales packaging such as cans, bottles, canisters, barrels with lubricating oils and a filling size greater than 0.8 litres
Filling materials containing harmful substances are only those substances, mixtures and products specified in more detail in Annex 2 to Section 3 (7) of the Packaging Act. These are primarily:
Substances and mixtures that would be subject to the self-service ban under the Chemicals Prohibition Ordinance if sold in retail outlets,
Plant protection products for professional users,
Certain respiratory sensitising mixtures,
Certain oils, liquid fuels and other oil-based products.
If collection points (retail, trade, industry) commission you as the responsible manufacturer with a take-back request, we, as the dual system with the most experience on the market, will be happy to carry out a needs-based take-back for you.
After you have designated such a collection point, we will organise the one-off or regular take-back and proper disposal & recycling on your behalf.
Provision of a return system for transport packaging by one of the most renowned and experienced providers, GreenDot.
You will have access to our convenient reporting system, which allows you to handle all aspects of your contract management in a time-saving manner.
Collection of customer packaging from the registered collection points by GreenDot in accordance with requirements.
We would be pleased to advise you transparently on our comprehensive recycling solutions and provide you with non-binding quotations.
If you only place packaging on the market that is not subject to mandatory participation in a system (such as transport packaging, industrial packaging, reusable packaging and returnable single-use beverage packaging), you are not required to submit any reports on your packaging quantities (data reports). However, certain take-back, recycling and documentation obligations apply to packaging that is not subject to mandatory participation in a system. Details can be found in Section 15 of the Packaging Act.
Exception: Companies that are required to submit a declaration of completeness due to their packaging quantities must also state the quantities of their industrial sales and outer packaging in the declaration of completeness, in addition to the quantities of sales, outer or shipping packaging subject to system participation. This information is mandatory.
Companies with high packaging volumes must submit an audited declaration of completeness for the previous year by 15 May each year. The audit must be carried out by an auditor registered with the Central Agency Packaging Register (ZSVR). If the deadline falls on a weekend or public holiday, the submission deadline is postponed to the next working day. An extension of the deadline is not possible. The declaration of completeness must contain information on the type of material and mass of all sales and outer packaging placed on the market in the previous calendar year – including those that become waste after use in industry or large-scale commerce.
The obligation to submit a declaration applies to companies whose packaging quantities in the previous calendar year reached or exceeded at least one of the following three thresholds:
Glass: 80,000 kg
Paper, cardboard, carton (PPC) in total: 50,000 kg
Ferrous metals + aluminium + plastics + beverage carton packaging + other composite packaging (LWP) in total: 30,000 kg
Even if these thresholds are not reached, the ZSVR and the competent state authorities are authorised to demand the submission of a declaration of completeness at any time.
Important!
Even after the deadline has expired, the declaration of completeness must be filed in the LUCID packaging register. Late submission, as well as failure to submit, constitutes an administrative offence punishable by a fine.
Application for clarification of the obligation to participate in a system for packaging:
If you are unsure whether certain packaging must be licensed with a dual system (i.e. is subject to system participation), you can submit an official application free of charge to the Central Agency Packaging Register (ZSVR). The decision will then be made in the form of an administrative act.
Check beforehand: The packaging catalogue
Before you submit an application, it is worth taking a look at the catalogue of packaging subject to system participation. This catalogue contains the most common types of packaging and shows whether or not they are subject to system participation. It is considered an authoritative guide and is published as an administrative regulation.
Prepare your application correctly:
If you still wish to submit an application:
Please read the information sheet and application forms provided by the ZSVR in advance.
There you will find all the requirements and information you need to submit your application.
Good preparation helps to avoid delays and speed up processing.
