Do you have questions about the Declaration of Completeness? Or would you like to know what consequences you face from the 6th and 7th amendment of the German Packaging Ordinance? Which regulations apply to retail and online retail in particular? Here you’ll find the answers.
By the way: Questions about the proper separation and everything related to the Green Dot for consumers can be found here.
The dual system is relevant for both retail and online retail. If you trade with sales packaging filled with goods which are normally purchased by end consumers, you are obliged to participate in a dual system such as Der Grüne Punkt for the disposal of such packaging. These systems operate on the legal basis of the German packaging laws.
The costs for participation in the German dual system of DSD GmbH depend on the packaging material used and the weight of sales packaging entered into the market. The minimum payment to participate in the dual system of DSD GmbH is 140.00 € net / year.
To calculate an offer you can use our convenient customer program
By concluding a participation agreement with DSD GmbH. To register, please use the internet portal Online-Service. It contains all important information required for your business, and you can conclude your agreement with us online.
The German packaging ordinance is based on the “Act for Promoting Closed Substance Cycle Waste Management and Ensuring Environmentally Compatible Waste Disposal” and takes into consideration European directives for the return and disposal of packaging. The objectives of the packaging ordinance are to avoid or reduce the impact of packaging waste on the environment, and to make a contribution towards protecting natural resources by recycling.
Since 1st January 2009 manufacturers and distributors of sales packaging who bring such packaging into the market for the first time (first circulators) are obliged to participate in a dual system. For service packaging (e.g. shopping bags, baker’s bags etc.) the participation obligation can be delegated once to a preliminary sales level (manufacturer, distributor, pre-distributor).
The submission of a so-called Declaration of Compliance was also introduced for the first time with the 5th amendment to the packaging ordinance (VerpackV).
The 6th amendment of the Packaging Ordinance (VerpackV) came in force on July 24, 2014 and matches the German law with the regulations of the European Union. The key aspect of the 6th amendment is the clear demarcation of products and sales packaging regarding, e.g. winding cores of sanitary paper (sales packaging), planting pots (sales packaging) and toner cartridges (no sales packaging).
The 7th amendment should avoid a destabilization of the German recycling system by preventing the abuse of the system by using loopholes in the packaging ordinance regarding industrial specific solutions and point of sale take back solutions. As such, the key aspects of the 7th amendment are that the regulations regarding the point of sale take back solution do not longer apply since October 1st, 2014, and the new regulations regarding the industrial specific solutions apply since January 1st, 2015.
The German packaging ordinance does not specify any minimum volumes, below which the regulations do not apply (de-minimis rule). As such, all sales packaging circulated in the territory of the Federal Republic of Germany is subject to the packaging ordinance, even small amounts of such.
The German packaging ordinance (VerpackV) only applies in the Federal Republic of Germany. Since this involves implementation of the European packaging directive within national law, separate national laws for package labelling, registration etc. apply in other countries of the EU.
Further information is available at:
The current packaging ordinance text is available on the website of the German Federal Ministry for Environment, Nature Conservation and Reactor Safety at the following link.
A dual system is a secondary disposal system and was set up – in addition to the public waste disposal system – exclusively for used sales packaging. In 1990 „Der Grüne Punkt - Duales System Deutschland GmbH (DSD)“ was founded as the first dual system which has developed today’s household collection system in Germany. By order of its customers, DSD GmbH organizes household packaging waste collection (via the yellow bin / yellow bag, containers for glass etc.) and ensures professional sorting and recycling of packaging. This way our dual system contributes substantially to saving limited resources and fighting environmental pollution.
The disposal services (collection, sorting and recycling of sales packaging) are financed via participation payments and are executed by commissioned disposal companies.
Private end consumers in the terms of the packaging ordinance are households and so-called comparable sources of waste packaging, especially restaurants, hotels, canteens, administration centers, barracks, hospitals, educational centers, charities, freelancers and typical cultural sites such as cinemas, operas and museums, as well as the leisure-time sector such as vacation camps, leisure parks, sports stadiums and restaurants.
Comparable sources of waste also include agricultural and craftsmen businesses which can be disposed in a waste collection cycle typical for households via household collection bins for paper, cardboard, cartons and light packaging using a transfer bin for not more than 1,100 litres per material group.
Manufacturers and distributors who distribute sales packaging filled with goods to the above-mentioned sources of waste in Germany are obliged to participate in a dual system.
For all those who act as first circulators (bringing packaging into the market for the first time), the participation in a dual system is mandatory. If you trade with sales packaging filled with goods which are normally purchased by end consumers, you are obliged to participate in a dual system for the disposal of such packaging. So the dual system is relevant e.g. for both retail and online retail.
Manufacturers and distributors who do not register their sales packaging within a dual system against their duty, are acting contrary to regulations. This may result in a civil fine.
The word ‚participation’ is a term from the packaging ordinance Germany. ‘Participation in a dual system’ means that the manufacturer and distributor of sales packaging filled with goods which normally accumulates at the private end consumer must participate in one of several dual systems in order to ensure national return of such packaging. The collection, sorting and recycling of sales packaging entered into the market is thus financed via so-called ‘participation payments’ which are made to the dual systems. The Green Dot system is the oldest and biggest dual system in Germany.
If you have been putting packaging onto the German market which is subject to the mandatory participation in a dual system, you have to continue the participation. You would like to continue your business in Germany after January 1, 2019? Then you are obliged to register with the newly founded “Central Packaging Registry” before the law becomes effective. Please note: You have to register before dispatching anything onto the German market for the first time.
Find out more about the rules and regulations of the German Packaging Act: here
The costs for participation in the dual system of DSSD GmbH depend on the packaging material used and the weight of sales packaging entered into the market. The minimum payment to participate in the dual system of DSD GmbH is 140.00 € net / year.
To calculate an offer you can use our convenient customer program
The dual system of DSD GmbH has been set up nationally in the Federal Republic of Germany since 1993 and organizes the collection, sorting and recycling of sales packaging. On participating in the dual system of the DSD GmbH, observance of appropriate participation duties from the German packaging ordinance is guaranteed.
By concluding a participation agreement with DSD GmbH. To register, please use the internet portal Online-Service. This contains all important information required, and you can conclude your agreement with us online.
Sales packaging is packaging offered as a sales unit and which accumulates at the private end consumer, i.e. in private households and comparable sources of waste. Sales packaging also includes so-called service packaging, i.e. packaging from the trade, gastronomy and other service providers which enable the handing over of goods to the private end consumer (e.g. shopping bags, baker’s bags etc.) as well as disposable plates etc.
Since each packaging which accumulates at the end consumer is defined as sales packaging, this also especially includes shipping cartons e.g. from online retailers, filling material and even shopping bags. These are often wrongly defined as transport packaging.
Pursuant to the German packaging ordinance, manufacturers and distributors of sales packaging filled with goods which are normally passed on to the private end consumer are responsible for having the collection, sorting and recycling executed via a dual system.
Transport packaging is packaging which facilitates the transport of goods, protects goods during transport or is used for reasons of safety of transport and which accumulates at the distributor (e.g. the trade). The decisive factor is that the packaging ends up at the distributor and not at the private end consumer. Transport packaging can therefore include, for example, pallets, shrink-foil and boxes with several sales units which merely serve for transport protection and which end up at the distributor. Packaging used for transport purposes which accumulates at the end consumer – e.g. shipping cartons from online sales - does not count as transport packaging.
The difference is in the location where the used packaging ends up for disposal (source of waste). Transport packaging ends up at the distributor (e.g. the trade) and sales packaging at the private end consumer, e.g. household, restaurant etc.
The regulations for transport packaging defined in the packaging ordinance do not fundamentally change with the new packaging law coming into effect. As of January 1st, 2019, the mandatory participation in a dual system still does not apply to transport packaging.
Manufacturers and distributors are responsible for the disposal of used transport packaging.
Der Grüne Punkt – Duales System Deutschland GmbH also provides a waste management service for transport packaging.
You will find further information here.
Costs for the disposal of transport packaging depend on the packaging material of the entire transport packaging used. The minimum payment is 250 € net / year. We can submit an individual quotation, on request. Simply fill in our questionnaire at:
Shipping packaging is "shipping material used for the transport of goods and which accumulates at the end consumer (especially shipping packages from online retail and mail-order trade, including direct selling). Shipping packaging is to be categorized as sales packaging" (Source: www.laga-online.de) and is therefore not categorized as transport packaging.
Manufacturers and distributors of shipping packaging are responsible for disposal. Since shipping packaging is sales packaging in terms of the German packaging ordinance, participation in a dual system is also obligatory for shipping packaging.
When using used packaging, e.g. used cardboard boxes in internet trade, there is also an obligation to participate in a dual system. Exceptions apply if the used packaging has already been registered with a dual system pursuant to § 6 sect. 3 VerpackV, but has not yet been disposed of. Burden of proof is with the person/company which places the sales packaging filled with goods into the market.
To register, please use our internet portal „Online-Service“. This contains all important information needed about shipping and sales packaging, and you can directly enter into an agreement with us online.
This is the link to our program
Service packaging is packaging of the trade, gastronomy and other service providers which enable the passing on of goods to private end consumers (e.g. shopping bags, baker’s bags, etc.).
In principle, the company initially entering such packaging into the market. In the case of service packaging, the packaging ordinance specifies the exception that obligation to participate in a dual system can be delegated once to a preliminary sales level (manufacturer/ distributor or pre-distributor).
Final distributors of commercial or industrial packaging, have to accept free of charge used and emptied sales packaging returned by the final consumer and to consign it to recovery (§ 7 Packaging Ordinance). Commercial or industrial packaging are sales packages which do not accumulate with the private end consumer or comparable sources of waste. It can be returned at or in the immediate vicinity of the place of actual transfer.
Der Grüne Punkt can support you in complying with your obligations entailed by the provisions of the German Packaging Ordinance for dealing with used commercial and industrial packages.
According to § 7 Packaging Ordinance commercial and industrial companies are obliged to take this form of package back free of charge. Furthermore there are the following obligations regarding commercial and industrial packaging: evidenced recovery of all packages taken back, complete mass flow verification (issue, collection, recovery).
Yes, the disposal of commercial and industrial packaging is part of our portfolio.
Please feel free to send us a non-binding inquiry: here
DSD GmbH currently does not provide a disposal service for batteries.
Since 1. May 2005 deposit duty has applied for disposal beverage packaging in the following beverage sectors:
|1.||Beer (including alcohol-free beer) and beer mixed beverages,|
|2.||Mineral, spring, table and medicinal water and all other drinkable water,|
|3.||Refreshment drinks, sparkling and non-sparkling (especially lemonade including cola beverages, fizzy drinks, bitter drinks and ice-tea). Not included in refreshment drinks in terms of sentence 1 are fruit juices, fruit drinks, vegetable juice, vegetable drinks, beverages with a minimum share of 50 per cent of milk or products generated from milk, and mixes of such drinks as well as diet drinks in terms of § 1 sect. 2 letter c of the Diet Regulations provided exclusively for babies or small children,|
|4.||alcoholic mixed beverages which|
|a)||have been produced using|
|aa)||products subject to duty on spirits pursuant to § 130 Abs. 1 of the law on Spirits Monopoly, or|
|bb)||fermentation alcohol of beer, wine or products similar to wine, also in processed form which has been subjected to technical treatment which no longer complies with good production practice and has alcoholic strength of less than 15 %, or|
|b)||contain less than 50 per cent wine or products similar to wine, also in processed form.|
Deposit duty applies to manufacturers and distributors of disposable beverage packaging which is not ecologically advantageous.
The following disposable beverage packaging is considered as ecologically advantageous and is therefore not subject to a deposit:
You will find more information and our offer concerning DSD deposit duty here.
The ElektroG includes:
A complete list is available in § 2of the ElektroG.
The manufacturer of electrical and electronic equipment , or company which first places the product with packaging into the market (if the manufacturer does not have a registered location in an EU member state), is responsible for disposal.
Those subject to the law are obliged to take on equipment collected by local authorities, to recycle such equipment in accordance with ecological standards and to bear the costs. Depending on the respective equipment category, 70 to 80 weight per cent are to be recycled, at least 50 weight per cent is to be re-used or its material recycled.
Manufacturers pursuant to § 3 sect.. 11 and 12 ElektroG are all companies which, within the scope of the Act:
The local authorities provide collection containers for electrical and electronic equipment which are filled with waste equipment of the end consumers. When these are full, the local authority contacts the Foundation Elektro-Altgeräte-Register (EAR) (Electrical Waste Equipment Register), which then issues a collection order to one of the registered manufacturers in accordance with a specific distribution key. The appropriate collection container must be collected within a period of four days.
If you have commissioned Der Grüne Punkt – Duales System Deutschland GmbH in the EAR system as a disposal company, we will handle operations for you accordingly.
You will find further information and the link to EAR here.
All electrical equipment placed on the market must be labelled permanently with this symbol for identification purposes.
Your company has to handle registration with EAR.
The insolvency-proof guarantee is specified by law and provides security for the community of manufacturers in the case of insolvency of the manufacturing plant of electrical and electronic equipment.
We can arrange an insolvency-proof guarantee for you for the financing of the return, recycling and disposal of your B2C equipment.
Within the scope of facility waste management, production waste, organic waste, special or packaging waste is disposed at the location of the company or in branches or a branch network.
The DSD facility waste management system is intended for both manufacturers and distributors.
You can find more information here.
To enquire, please use our Online questionnaire. We can provide you with a tailor-made disposal concept and submit you an individual offer.
European Packaging Directive/The main objectives of the European packaging objectives are the avoidance and reduction of environmental impact from packaging and packaging waste – with the concrete target of reducing packaging waste across Europe by 50 per cent. Other principles in the directive include the re-use and recycling of packaging waste in terms of material and energy.
The directive specifies outline conditions and contents which all member states of the European Union have to implement into national law. As a result, each member state must execute the action required for the setting up of return, collection and recycling systems for used packaging. However, each country is at liberty to organize such systems itself.
National implementation of European law in Germany is manifested in the German packaging ordinance. This specifies that manufacturers and distributors of sales packaging filled with goods, which normally end up at the private end consumers, are responsible for the collection, sorting and recycling of their packaging. Such duties are completely fulfilled by participating in a dual system. The German packaging ordninance will be replaced on January 1 st, 2019, by the German packaging act.
There are now 31 members active across Europe under the umbrella of PRO EUROPE; 29 of these use the Grüner Punkt trademark as a licensing symbol for packaging recycling. In addition, PRO EUROPE has entered into a cooperation agreement Green Dot North America to ensure that legitimized license holders of the Grüner Punkt can distribute their packaging labelled with the symbol without any problems also in the NAFTA area.
You can find current information on the international use of the trademark „Der Grüne Punkt“on the website of the umbrella organisation PRO EUROPE.
Pursuant to the packaging ordinance, there has been no obligation to label packaging since 2009. However, labelling of packaging is useful and is still used by most companies placing packaging filled with goods onto the market for the first time. Der Grüne Punkt indicates to the end consumer that the respective sales packaging can be disposed via the yellow bin or yellow bag, etc.. In addition, the trademark „Der Grüne Punkt“ shows that customers take their producing responsibilities seriously and fulfil their obligations in line with the packaging ordinance.
To use the trademark, „Der Grüne Punkt“ you need to acquire a trademark license in the country ion which packaging labelled with the Grüner Punkt is distributed. To use the trademark, „Der Grüne Punkt“ in Germany, you need to conclude a trademark licence agreement with Der Grüne Punkt – Duales System Deutschland GmbH. Another precondition is that the manufacturer/distributor fulfils the legal targets for such sales packaging, especially participation in a dual system.
No, the German trademark licence agreement is only valid for the use of the trademark „Der Grüne Punkt“ in Germany.
An obligation to label exists in the following countries:
When you export packaging filled with goods into these countries, your packages have to be labelled.
The German packaging ordinance is the implementation of the European Packaging Directive into German law and is only effective on the German market. Thus, the packaging ordinance is not only relevant for the German retail and online retail, but for manufacturers and distributors whose sales packaging accumulates with the end consumer and comparable sources of waste on the territory of the Federal Republic of Germany as well.
DSD GmbH offers contracts for the following services:
In order to use the trademark „Der Grüne Punkt“ for sales packaging distributed on the territory of Germany, you have to conclude a Trade Mark contract with DSD. The fees for the isolated trademark use “Der Grüne Punkt” (”The Green Dot”) are:
((all prices net)
By concluding a Trade Mark contract, you acquire the right, against payment, to use the trademark „Der Grüne Punkt“ on all packaging covered by the agreement. Please note that this contract does not include the required participation in a dual compliance scheme for packaging as prescribed in the German Packaging Ordinance.
To register your packaging for participation in the dual compliance scheme of DSD you have to conclude a contract for participation (Beteiligungsvertrag). The trade mark contract and participation contract can be concluded independently.
You can conclude participation and/or trademark agreements directly online via our internet portal:
You can conclude participation and/or trademark agreements directly online via our internet portal Online-Service.
We can submit an individual offer concerning our other services. Simply get in touch with us!
We do not provide any special contracts for smaller companies.
A declaration of compliance is a verification concerning the volumes of sales packaging placed into the market by a manufacturer / distributor within one calendar year, and has to be submitted to the respective local Chamber of Industry and Commerce (CIC) by 1st May for the previous calendar year.
Data is to be audited by a tax consultant, auditor, certified accountant or independent expert and verified by electronic signature. The volume data is transferred into a database by the company first placing the sales packaging into the market, under www.ihk-ve-register.de released by the respective CIC and is only available to inspection authorities.
Generally speaking, the initial circulator of the sales packaging that is intended for the private end user or a comparable waste collection point is obligated to create and submit the DoC. If and when the submission of a DoC is required, this must be done digitally by the initial circulator at www.ihk-ve-register.de.
For service packaging, these are the distributors who initially fill the packaging with goods as long as they have not delegated the duty of compliance to the manufacturer or a pre-distributor.
If an initial circulator also puts the sales packaging for commercial end users into circulation (§ 7 German Packaging Ordinance), he needs to assume the specifications on the fulfillment of the recovery requirements stated in the DoC.
In addition, both the specifications to the amounts as well as to the person responsible for submitting the material-flow balance are to be done as part of the participation in an industrial sector solution in the DoC form.
Content and scope of the declaration of compliance result from the packaging ordinance (§ 10 VerpackV). This especially has to include data on type of material and mass of all sales packaging entered onto the market in the previous calendar year. These are divided into:
The DOC has to be submitted by May 1st of each calendar year for the previous calendar year.
Regulation for submission of the DOC is based on minimum volumes. The certified declaration of compliance is to be submitted each year, if the following volumes of packaging placed into the market are exceeded:
|Glass||› 80,000 kg/year or|
|Paper, cardboard, boxes||› 50,000 kg/year or|
|Other*||› 30,000 kg/year|
|(*Aluminium, plastic, compounds, tinplate)|
As soon as these limits have been exceeded, a DOC has to be submitted for all packaging materials! If the annual volumes are below these minimum volumes, the declaration of compliance only needs to be submitted if requested by the local authority.
Regular drawing up of the DOC is not necessary if the annual volumes are below the minimum volumes per packaging type. However, respective data must be available at all times because the local authority can demand such a DOC at any time. The most important factor is that the company first entering sales packaging onto the market keeps the necessary data up to date and available, even if it stays below the minimum volumes.
If required submission of the DOC is not made, a fine of 50,000 € is possible. The local authority can also order appropriate administrative fines. The DOC must be subsequently drawn up, so that there is no benefit resulting from non-submission in the first place.
No. On presenting the certificate agreed by contract between the customer and Der Grüne Punkt – Duales System Deutschland GmbH, the data provided by the customer in the annual closing report are confirmed in terms of correctness and completeness.
In contrast, the legally specified declaration of compliance covers all packaging entered into the market which accumulates at private and commercial end consumers.
More information on the procedure concerning the declaration of compliance is available at http://www.ihk-ve-register.de
Yes. If the minimum volumes specified in § 10 sect. 4 of the German Packaging Ordinance are exceeded in one or several material sections, the declaration of compliance must be submitted without request and within the deadline by 1st May for the previous year. Data is entered into the database by the company first placing packaging into the market, and formally checked. Advance auditing by an auditor, tax consultant, certified accountant or independent expert is required.
The declaration of compliance is to be transmitted to the respective regional CIC by 1st May for the previous calendar year via a specified digital path.
You can find all information required for the transfer of data to your CIC at www.ihk-ve-register.de.
The respective regional CIC publish the names, post code and federal state/country of the companies which have submitted a DOC on an internet platform of the DIHK (German CIC). Other information is not accessible for third parties. Only inspection authorities can inspect the DOC within their authorization to execute inspection.