German Packaging Act - 14. September 2018

Who is a „manufacturer“ and what is a „packaging“ within the meaning of the Packaging Act?

Shipping cartons for self-sewn items are also packaging for private final consumers.

The new Packaging Act 2019 (VerpackG) obliges manufacturers to take care of the disposal of their packaging. However, the act does not mean the manufacturer of the packaging, because the one that commercially places packaging on the market for the first time is considered to be a manufacturer. He fills the honey into the jar or packs the dress for shipping by mail. A responsible manufacturer in the sense of the Act is also the one who imports honey or a dress already packed from abroad to Germany, thus actually a dealer or online dealer, but who the law also defines as a manufacturer.

A manufacturer is…

  • the initial distributor who professionally places packaging on the market
  • also the one that introduces packaging professionally into the scope of application of the Packaging Act (import of packaged goods).

Essentially, the act deals with packaging which is „typically offered to the final consumer as a sales unit composed of goods and packaging”. This also includes the cardboard box and the cushion foil in which the online retailer packs his goods and takes them to the post office for dispatch. It is irrelevant if the packaging actually ends up with the final consumer. In any case the packaging needs to be licensed under a dual system so that the consumer has the option of placing it in the recycling bin at home.

Packaging are…

  • sales packaging which are typically offered to the final consumer as a sales unit composed of goods and packaging,
  • sales packaging that is only filled by the last distributor in order to enable or support the handover of goods to the final consumer (service packaging) or enable or support the dispatch of goods to the final consumer (dispatch packaging).

By the way: Packaging for private final consumers that do not participate in a dual system may not be distributed at all.

Should there still be any open questions – the competent customer service team of Der Grüne Punkt will be glad to be of help: kundencenter(at)

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If you sell honey commercially, you are a manufacturer in the sense of the Packaging Act.