With the PPWR and the German Packaging Law Implementation Act (VerpackDG) now in effect, the European Commission has published an important FAQ document clarifying the new regulations. Accordingly, responsibility for plain, unprinted standard boxes usually remains with the company that manufactures or supplies the packaging. This does not change if the retailer assembles and fills the box. A dispatch label is for delivery purposes and is not considered brand labelling.
The situation is different for customised packaging. If a box carries the retailer’s name or brand, the retailer may be considered the manufacturer and may therefore assume additional obligations, such as registration and participation in take-back and recycling schemes. Furthermore, according to the European Commission, the addition of adhesive tape, film or filling material does not automatically make the retailer responsible for the entire packaging. So, anyone who uses neutral standard cardboard boxes and merely affixes dispatch labels is, in principle, not regarded as a packaging manufacturer. However, a final legal clarification is still pending.
Do you have questions about the PPWR and your new obligations? Our trade-e-bility advisory team will be happy to make you a suitable offer.
