Distributor-Finder_2019_2020_EN

Focus Packaging Act
Not much has changed for us compared to previous years. After
all, the packaging of all the goods we sell is reported to a
system – as we have done before – no matter who is indicated
on the packaging as the manufacturer and where the delivery is
going. We consciously ignore the principle of “whoever appears
on the packaging must pay” in order to
minimise bureaucracy. If a customer
receives any inquiries, we can conveniently
prove that we have paid. We avoid many
difficulties and the customer is on the safe
side. In principle, we welcome the concept
of paying for resulting waste, even if the
whole procedure is a little annoying …
“We continue to license all
packaging and avoid any difficulties.”
Dennis Dennig, Jung since 1828
>> Distributors are also affected
Let us follow the path that a product can
take in the supply chain. A consignment
has arrived in Germany. We can assume
that packaging of powerbanks, tools or bags
has already been licensed by the producer or importer.
The cartons in which the goods were delivered are considered
to be transport packaging, they do not end up at
the end user and are therefore not subject to system participation.
The products are now resold through the promotional
product distributor. He then packs parts of the
consignment together with other products in new packaging
to send to his customers. In this case, he places this
new package in this form on the market for the first time
and thus has to license shipping packaging provided it ultimately
ends up at the end user. The same applies if a distributor
repacks products previously packed in decorative
or individually designed packaging. Even though this packaging
is used differently for a while, it must also be licensed.
Even used packaging must be licensed by the distributor.
The new Packaging Act is not all that new: It applies to all
companies that were previously required by the Packaging
Ordinance to ensure the collection and recycling of the
packaging of their commercially sold products – if they end
up at the end user as waste. Therefore, it also obligates
promotional product companies when their products meet
certain requirements. What is really new is that at the same
time they have to report the
information they provide to the dual
systems to the new packaging
register, which is publicly accessible. If
you make the effort, you can find free
riders and bring them to justice. For
all those who have already acted in accordance with the law,
the Packaging Act is actually good news because the
system should ensure that the costs of disposal and
recycling are now distributed more fairly.
This obligation is only waived if proven that it has already
participated in a system. Distributors must always be able
to prove that a certain packaging has already been licensed.
In principle, the end distributor in Germany must ensure
that the obligations under the Packaging Act are complied
with. Whenever it is uncertain whether a product is subject
to system participation, it makes sense to include a
suitable line of reasoning in the product files. In case of
doubt, those affected can explain why they did not license
their product.
N
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“Not much has changed for anyone
who has acted correctly so far.”
Lutz Gathmann, designer
Full service and direct-to-customer business
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