Sales packaging: recycling and take-back
European packaging legislation requires initial distributors of sales packaging to honour their product responsibility and register their packaging with a recycling system provider (dual system) for collection and recycling.
Interzero Recycling Alliance – a strong partner for sales packaging
Do you manufacture products whose packaging ends up as waste at private households? If so, help is at hand from the self-contained recycling system offered by environmental service specialist Interzero: we organise the professional and legally compliant take-back and recycling of your packaging. Interzero helps you fulfil your obligations from packaging ordinance while also ensuring you meet the stringent standards for documentation. Learn more
And for distributors of smaller quantities of packaging, orders can even be placed online in our user-friendly shop.
Recycling by Interzero – your benefits at a glance
Service-oriented
A local team of our experienced inside and field sales staff is on hand to answer your questions.
Reliable
We act as guarantors for your declaration of compliance, i.e. your annual statement of packaging distributed as required by law in Germany.
Sustainable
We recover valuable raw materials from your recycled packaging. In addition, our customers also receive an annual Resource Protection Certificate as a sign of their active environmental engagement.
How the Central Agency Packaging Register works:
The German Packaging Act (VerpackG), inti force since 1 January 2019, usher in a number of changes. A body referred to as the Central Agency Packaging Register has been established, and takes over the duties of the Association of German Chambers of Commerce and Industry (DIHK) in terms of providing a platform for declarations of compliance. Manufacturers are faced with a number of changes, such as mandatory registration and the duty to report data (sections 9 and 10 of VerpackG). A How-To Guide provides information about duties related to product responsibility and the registration procedure. Those facing registration for the first time can find answers here to the ten most important questions regarding Packaging Act compliance. Our FAQ also provides further details.
Managing Director Interzero Recycling Alliance GmbH
Frequent questions of our customers
- What is the Packaging Act (VerpackG) and what role is played by the Central Agency Packaging Register?
On 1 January 2019, the Packaging Act (VerpackG) will replace the previously applicable Packaging Ordinance (VerpackV) in Germany. Anyone who distributes packaging that ends up as final consumer waste is responsible for the collection and recycling of this packaging. E-commerce merchants are also included. The Packaging Act is intended to change the behaviour of those required to register so that packaging waste is primarily avoided and can be collected in preparation for reuse or recycling. Apart from significantly raising targets for mechanical recycling, a number of duties and definitions have also been added by the new Packaging Act.
The Act requires the manufacturers and distributors of packaging to register with the newly created database named LUCID. Tasks allotted to the Register include:
- Manufacturer registration before placing packaging on the market
- Handling data reports from manufacturers and systems
- Repository for declarations of compliance
- Comparison and auditing of data reports
- Maintenance of an auditor registry (appraisers, financial auditors, tax advisors, registered accountants)
The centralised auditing of all packaging licensing by the new supervisory body will be considerably more efficient and create greater transparency for all market participants.
- What is a Declaration of Completeness?
The Declaration of Completeness forms part of the Packaging Act. It is defined in article 1 of the Act and is aimed at those who place sales packaging on the market. Every year, these persons must submit a Declaration of Completeness by May 15, which states how many items of packaging filled with goods they placed on the market during the previous year.
This Declaration must be audited by a financial auditor or tax advisor and filed with the local Chamber of Industry and Commerce (IHK). Alongside the material type and volume of packaging placed on the market, the Declaration of Completeness must also state the locations where waste is generated (private or commercial) and how take-back is organised (commercial waste management system or industry-specific solution).
Some distributors are exempted from completing the Declaration of Completeness, however. If they do not exceed certain de minimis limits, the Declaration must only be submitted if required by regulators. These limits are 80,000 kg for glass, 50,000 kg for paper, paperboard and cardboard, and 30,000 kg for lightweight packaging (plastics, composites, tinplate, aluminium) per annum. - What are the new rules on mandatory registration (section 9 Packaging Act)?
According to the new Act, manufacturers are required to register with the newly created Central Agency Packaging Register before placing packaging on the market. Applications for the registration number required should be made well in advance of 1 January 2019 at https://www.verpackungsregister.org/. Packaging that is not correctly registered may not be offered for sale.
Almost all details that manufacturers disclose as part of their participation in the system must be communicated to the Central Agency´s database LUCID by manufacturers themselves and, as a minimum must include:
- Manufacturer’s name, address and contact details
- Appointment of a natural person as authorised representative
- Manufacturer’s national ID number, including the manufacturer’s European or national tax number
- Brand names used by the manufacturer to place its packaging with mandatory system participation on the market
- Declaration that the manufacturer fulfils its take-back obligations by participation in one or more systems or one or more industry-specific solutions
- Declaration that the details given are true
According to section 9 of the Act, third parties may not be contracted to perform registration. All registered distributors are published on the website operated by the Central Agency Packaging Register.
- What are the new rules on mandatory data reporting (section 10 Packaging Act)?
The Act requires manufacturers to report the details they have disclosed as part of system participation directly to the Central Agency. The following minimum data set must be reported:
- Registration code
- Material type and volume of packaging involved
- Name of the recycling system in which the manufacturer participates
- Period of time in which system participation occurred
Even distributors of small quantities must report their data to the Central Agency. According to section 10 of the Act, third parties may not be contracted to submit data reports. Since the recycling systems must also report their data to the database LUCID, direct comparisons of data can be made.
- What is meant by appying ecological criteria to licence fee pricing (section 21 Packaging Act)?
The Act requires the dual systems to take ecological criteria into account when drawing up their schedules of participation fees. This incentive aims to motivate manufacturers to use packaging that is especially recycling-friendly. Many kinds of packaging can already be designed to meet these criteria. Interseroh+ will be happy to help you optimise your packaging in a sustainable manner based on a recognised assessment standard. We use a scientifically sound assessment method to offer suggestions for improvement for recycling-friendly packaging design and advice on the use of high-quality recycled plastics.
Pan-European packaging licensing
