Sales packaging, repackaging and dispatch packaging of textiles, shoes, leather goods such as (Women’s) outer wear and accessories such as gloves, bags and fashion jewellery are mainly purchased by private consumers. Accordingly, they are generally obliged to participate in the system provided under the Packaging Act. Several fashion boutiques of a foreign fashion brand which are affiliated under company law with their own direct sales (online shops) and are based in Germany have not fulfilled their product responsibility for packaging and have violated their obligations under packaging law for years now. The German Foundation Central Agency Packaging Register (ZSVR) has notified the competent state enforcement authorities that there are concrete indications of regulatory offences having been committed. Possible consequence of such administrative offences include the imposition of fines, profit skimming, as well as monitoring the obligation to participate in the system retroactively for past periods.
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