On 1 January 2019, the new Packaging Act 2019 (Verpackungsgesetz, VerpackG) will replace the current Packaging Ordinance Act (Verpackungsverordnung, VerpackV). This raises important questions about sales of outer packaging, transport packaging, and packaging materials, especially for online shops in the German market. Even terms like mandatory participation, compulsory registration and the newly created Central Agency Packaging Register ('Zentrale Stelle Verpackungsregister') need to be clarified.
The Central Agency Packaging Register ('Zentrale Stelle Verpackungsregister') was established to implement the Packaging Act (VerpackG) and one of the important tasks of the register includes the provision of a platform for the declaration of compliance. However, other new requirements, such as the registration obligation pursuant to § 9 and the data reporting obligation pursuant to § 10 of the Packaging Act (VerpackG) for manufacturers and traders, are regulated by the Central Agency Packaging Register. The Central Agency has itself published a detailed list of the new obligations on product responsibility and a schedule for registration in a comprehensive How-To Guide (in German and English).
The new Packaging Act (VerpackG) applies to all distributors that bring packaging onto the market for the first time commercially in Germany (the so-called 'manufacturers'), i.e. national producers as well as importers, online retailers, etc. The law includes some new regulations and obligations or their modifications.
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