System participation – even for reusable carrier bags!

Even durable carrier bags may be subject to dual-system participation under the German Packaging Law Implementation Act. What matters is not whether a bag may be reused, but its original purpose. For many retailers, this decision may entail additional disposal and licensing costs.

On 23 July 2026, the Federal Administrative Court ruled that so-called permanent carrier bags are, indeed, packaging subject to system participation, as they are intended to transport purchases to the end consumer. Their durability or repeated use does not change this. The court also rejected classification as reusable packaging due to the lack of appropriate return and recycle structures. Anyone offering durable carrier bags should therefore plan for licensing and disposal costs and review their packaging compliance. In some cases, system participation obligations may also apply retrospectively.

Do you have questions about your system participation obligations? The trade-e-bility advisory team will be happy to provide a suitable quote.

Questions? Contact us now without obligation

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Sebastian Siebert
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Sebastian Siebert
Head of Advisory services

Phone: +49 40 750687-0

consulting@take-e-way.de

Christoph Brellinger
Contact

Christoph Brellinger
Head of Marketing & Public Relations

Phone: +49 40 750687-0

pr@take-e-way.de

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