On January 1st, 2019, the new Packaging Act came into force and replaces the previous Packaging Ordinance. Most of the obligations under the Packaging Act concern manufacturers of packaging. Although most distributors initially suspect, on the basis of common usage, that they are not manufacturers of packaging, the opposite is the case. The aim is to further promote the recycling of packaging waste and to avoid packaging.
Under Section 3(14) of the Packaging Act, the manufacturer is defined by the Packaging Act as ‘the distributor who places packaging on the market for the first time on a commercial basis’ or ‘the distributor who places packaging on the market within the scope of this Act’.
- Sign with the info “disposable” or “reusable” must be affixed near the beverage packaging at the point of sale.
The design and font size must at least correspond to the price labelling.
- This also applies to the mail-order business, which must now include the information in brochures or online shops.
Small direct marketers or retail shops such as kiosks are exempt from the labelling requirement, as the goods are predominantly handed over to the customer by service. Restaurants, canteens and vending machines, for example, are also not subject to the labelling obligation.
Non-compliance with the law can be punished with fines of up to 200,000 Euros.
Our labelling team will be happy to support you on the new regulations and will also carry out routine labelling inspections. Just get in touch:
T +49 30 206 038 384