What is transport packaging?
Transport packaging differs from conventional sales packaging in that it usually doesn’t end up as waste with the final consumer, but remains with the retailer. For this reason, transport packaging is not subject to mandatory participation. It is used exclusively for the transport of goods from business to business (B2B). Unlike packaging subject to mandatory participation, transport packaging does not have to be licensed by a dual system.
However, the German Packaging Act stipulates that transport packaging put into circulation must be taken back free of charge in the same manner, size and form as the producer put it into circulation, at the actual point of sale or in the immediate vicinity thereof. For the final distributor, this take-back obligation is limited to transport packaging of goods that are part of the distributor’s product range. In any case, there is a take-back obligation for transport packaging.
What are the specific obligations for transport packaging under the German Packaging Act?
In addition to specific take-back and recovery obligations, transport packaging is subject to further obligations, which are regulated and defined in Section 15 of the German Packaging Act (VerpackG).
Registration with LUCID
The amendment to the German Packaging Act, which came into force on 3 July 2021, defines new obligations for initial distributors of transport packaging. From 1 July 2022, distributors of packaging that is not subject to mandatory participation, such as transport packaging, must register with the LUCID Packaging Register. Producers who had already registered their packaging subject to mandatory participation on 1 July 2022 had to amend their registration and provide information on this additional type of packaging.
Please note that transport packaging only needs to be registered; packaging volume reports are not required.
Information, verification and documentation obligations
In addition to the take-back obligation, the German Packaging Act imposes information, submission, verification and documentation obligations on initial distributors of transport packaging.
Under the obligation to provide information, final distributors of transport packaging must inform final consumers about the return options and the reason why it should be returned. This information may be published on the manufacturer’s website, printed on the delivery note or displayed on a sign on site, at the manufacturer’s discretion.
The German Packaging Act imposes an obligation to provide verification and documentation. The producer has to provide proof of the quantity that was taken back and recovered in a report specifying the type of material and mass. This report must always be completed by the 15 May for the previous calendar year. Please note that submission is only required upon request by the competent regional authority.
In addition, producers and downstream distributors of transport packaging must have sufficient financial and organisational means available to fulfil their obligations under Section 15 of the VerpackG.
Your obligations: What you need to do
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Transport packaging versus sales and grouped packaging
To find out which obligations you have to comply with under the German Packaging Act (VerpackG), the first step is to identify the type of packaging.
Sales packaging that is subject to mandatory participation typically ends up as waste in private households. To help with classification, the Central Agency Packaging Register has drawn up a catalogue of packaging subject to mandatory participation. Any packaging of sales units that is listed as “sales packaging and grouped packaging” on the relevant product group sheets in the catalogue is not considered transport packaging.
Examples of what is not considered transport packaging:
- Bundling foil creating sales units (e.g. 10 0.33 litre bottles in a carry-out pack)
- Cartons creating a sales unit (e.g. 240 tubs of condensed milk in a folding carton)
- Multi-piece packs as sales units (e.g. 10 coffee capsules in a folding carton)
- Assortment packs as sales units (e.g. hobby products with separately packaged units in one carton)
- Packaging of sales units of electrical and electronic equipment, furniture and similar consumer goods (listed in the catalogue under sales packaging because it is considered a sales unit)
- Packaging of sales units of plumbing fixtures such as sinks, radiators, etc. (listed in the catalogue as sales packaging, because it is considered a sales unit)
[FAQ] Frequently asked questions about transport packaging
Transport packaging includes anything used to protect goods during transport, such as
wooden pallets, expanded polystyrene (EPS), foil, cardboard of all kinds, straps and adhesive tape.
Businesses that place transport packaging on the market are obliged to take it back under producer responsibility rules, i.e. they have a take-back obligation. This includes producers and downstream distributors. We are happy to assist you in complying with this obligation under the German Packaging Act.
No, you don’t. As of 1 July 2022, transport packaging must be registered with the Central Agency Packaging Register in the LUCID Packaging Register, but packaging volume reports are not required.