When goods are put into circulation, transport packaging may also be required. This must then be disposed of properly. The new German Packaging Act (VerpackG) has regulated the correct handling of this, including take-back and recycling, since 1st January 2019.
What is transport packaging and what regulations apply with the new German Packaging Act?
Transport packaging is used to transport goods from the manufacturer to retail according to the Packaging Ordinance. It protects goods from damage or is necessary for safety reasons. The new German Packaging Act also includes easier handling in the definition of transport packaging, which above all means improved storage and stackability. According to VerpackG, packaging is therefore regarded as transport packaging if it “facilitates the handling and transport of goods in such a way that direct contact and transport damage are prevented and is typically not intended for passing on to end consumers”.
The transport packaging category includes, for example, grouped packaging, cardboard boxes and pallets. Containers for road, rail, ship or air transport are not transport packaging.
Current legislation makes a significant distinction in the definition between transport packaging and sales packaging: while sales packaging is passed on to the end consumer, transport packaging is exclusively the responsibility of commercial retailers. For this reason, the new German Packaging Act also provides for exceptions in the take-back and recycling of transport packaging.
Obligation to take back and recycle transport packaging
As a general rule: anyone who puts packaging into circulation in Germany is obliged to take it back and, where technically possible and economically reasonable, to dispose of it or recycle it.
According to Section 15 of VerpackG, manufacturers and retailers are obliged to take back used, empty packaging of the same type, shape and size as the packaging they put into circulation free of charge at the place of actual handover or in its immediate vicinity and to reuse it or recycle it in accordance with the requirements of Section 16(5).
However, unlike sales packaging, transport packaging does not require proof of compliance with take-back and recovery requirements. Transport packaging is not subject to any obligation to participate in the system, i.e. there is no obligation to register with Stiftung Zentrale Stelle.
However, manufacturers and retailers can also fulfil the obligation to take back and recycle transport packaging by commissioning a service provider such as Deutsche Recycling. We also provide assistance for you at an international level and are always available to advise you.
Just get in touch with us! We will be only too happy to answer any questions you may have.