The German Central Agency Packaging Register (ZSVR) responded with a declaratory ruling to the enquiry by an insurance association as a distributor of letters with different contents. The insurance association wanted to obtain confirmation that the envelopes used, which had different contents, were not packaging items subject to mandatory system participation and that no licence fees were payable.
The ZVSR assesses this differently and classifies the envelopes as subject to mandatory system participation, adding that the decisive factor is their contents. If only notices and information such as invoices were sent, these would not be packaging items requiring mandatory system participation. If, however, in addition to an invoice, advertising flyers, brochures, leaflets and other printed advertising materials are sent, then the envelope is considered to be packaging filled with merchandise and is therefore subject to mandatory system participation. This applies irrespective of the envelope selected and concerns padded and classic envelopes featuring a window if they contain “merchandise”.
Further information in this regard is available on the website of the EUWID.
If you have any questions on the German Packaging Act, please do not hesitate to contact the take-e-way GmbH consultants by calling +49/40/750687-0 or by sending an e-mail to firstname.lastname@example.org.