Product Compliance for Your Nonfood Products

“With the application of the EU Packaging and Packaging Waste Regulation (PPWR) and the German Packaging Law Implementation Act (VerpackDG), the responsibilities relating to service packaging will change fundamentally. On the one hand, this will concern businesses that use this type of packaging and have their name, logo or brand printed on it. On the other hand, packaging manufacturers, importers and wholesalers may also have to fulfil packaging law obligations, depending on their role in the supply chain. What's more: in most cases, it will no longer be possible to fulfil these obligations by purchasing pre-participated service packaging”, the ZSVR (Central Agency Packaging Register) states.

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“Under the EU Packaging and Packaging Waste Regulation (PPWR), packaging used for online sales or other means of distance selling is considered e-commerce packaging. E-commerce packaging is categorised as transport packaging. Online retailers need to clarify whether they will be considered manufacturers as from 12 August 2026 and thus (as has often been the case in practice) producers because this would mean that they are responsible for packaging compliance and for financing packaging recycling, as well as for the associated registration and reporting obligations”, the ZSVR (Central Agency Packaging Register) states.

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Under the German Packaging Law Implementation Act (VerpackDG), registration and data reporting obligations cannot be delegated to third parties. However, Section 7 of the VerpackDG does not prohibit outsourcing the obligation to participate in a packaging scheme. As a result, this obligation may, in principle, be contractually assigned to a third party.

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