Attention: New obligations under the German Packaging Act

Documentation obligation for packaging not subject to system participation: Fulfil requirements of the amendment to the Packaging Act - start preparation for submission in 2023 now!

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The amendment of the German Packaging Act (VerpackG) this year has introduced extended verification and documentation obligations for producers within the meaning of the Act: In order to be able to serve future information obligations under the Environmental Statistics Act (UStatG), they must now also document all packaging not subject to system participation.

 

This includes

 

  • Transport packaging that accumulates in trade,
  • commercial and industrial packaging that accumulates at non-private final consumers, as well as
  • sales and outer packaging that is not compatible with the system,
  • sales packaging for products containing hazardous substances and
  • reusable packaging.

 

Broken down by material type and mass, the respective documentation must conclusively and comprehensibly show what was placed on the market and, if applicable, taken back and recovered. However, neither a specific form for the documentation nor an external audit are prescribed.

 

The documentation is to be kept by the manufacturer and is only to be submitted to the competent federal state authority upon request. The deadline for this is 15 May of each year for the previous year. It is therefore recommended to have provided the evidence for the calendar year 2022 by 15 May 2023.

 

This topic met with great interest in our online information events on German packaging legislation this year. We will continue this series of events in 2023. Find out more about this from the beginning of the year under www.gruener-punkt.de