Distributor-Finder_2019_2020_EN

Focus Packaging
The Packaging Act continues to cause uncertainty. For example, the
Central Packaging Registry (ZSVR) and the individual disposal
systems (Duales System, interseroh, etc.) do not provide a uniform
answer to the question of whether this or that type of packaging is
now subject to licensing. We tried it out and asked the same
question at three diff erent places – and got three diff erent
answers. Another problem: The Central Packaging Registry
announces very long response times for individual requests in
advance and immediately says that the information is not legally
binding. So we and many of our colleagues play it safe – we prefer
to license too much rather than too little as this
saves us a lot of administrative work.
Unfortunately, that is not cost-effi cient. In any
case, it is important to relieve the end
customer (as far as possible) of any burden.
Otherwise, we take the risk that our products
will end up becoming unattractive because of
bureaucratic hurdles. In any case, it pays to ask
several system providers because there are signifi cant price
diff erences here. In our case that was more than 1,000 euros.
“By licensing rather too much,
we take the burden off the customer –
also in our own interest.”
Tobias Köckert, Mahlwerck Porzellan
>> “Made by Beauty Company AG for Werbemittelprofi
GmbH” appears on the packaging, so Beauty Company
AG is subject to licensing. However, if Werbemittelprofi
GmbH appears on the packaging as the manufacturer,
then it is obligated – not the hotel chain. This
also applies if Beauty Company AG packs the goods
and delivers them directly to the hotels. Why? Because
it does not appear externally.
Special feature of service packaging
A special rule applies to service packaging, i.e. packaging
which is fi rst fi lled with goods where they are delivered
to the private end user. This includes, for example,
carrier bags made of paper or plastic, disposable tableware,
cling film and aluminium foil, bread roll bags, etc.
Only this packaging can already be purchased with system
participation, i.e. the initial distributor can transfer
its obligations to the supplier. Whoever uses this option
must not neglect to have the system participation confi
rmed by the packaging supplier (which, incidentally,
he is obligated to do). For the ind
bags are particularly relevant from
they are common and effective pro
tainability and transparency have
tant pillars of our corporate value
cling system is an inherent part of t
Managing Director of Bags by Riedle. “Therefore, we now
offer our customers a carefree package with pre- licensed
paper carrier bags. At the same time, Bags by Riedle handles
the entire process in accordance with the Packaging
Act, and the customer does not have to do anything else.
And proof for authorities is simply the invoicing of the order.”
The industry has thus already responded.
Product or packaging?
Especially for the promotional product industry which places
complex and innovative products on the market, it can
be a particular challenge to draw the line between the
product and the packaging. Classification according to the
Packaging Act will be correspondingly difficult. The defi-
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