Small but mighty: Licensing of packaging for small businesses
Every gram counts - even for small businesses!
Packaging stays packaging - no matter how large a company is that passes on packaged goods to private end consumers or comparable source of waste generations. The Packaging Act also places an obligation on small businesses and does not allow minimum quantity regulations or lower limits - all first-time distributors must license their grouped, sales and shipment packaging starting with the first gram.
Simply put: Small businesses are also obliged to register with the Central Agency, to participate their packaging in the dual system and to report the quantities to both.
It is quickly done with BellandDual: In just a few clicks, you can determine your participation fee with our non-binding licence calculator - and then decide whether to directly conduct a contract for the licensing of your packaging in accordance with the Packaging Act.
This is what the amendment to the Packaging Act means for you as a small business owner:
► Registration obligation for final distributors of service packaging: As a small business owner, you still have the option of delegating the system participation obligation for your service packaging to your upstream distributor. From 1 July 2022, however, all final distributors must register with the central body, irrespective of the system participation obligation.
► E-Commerce: From 1 July 2022, electronic marketplaces may no longer enable the offering for sale of packaging subject to system participation if its manufacturers have not participated in a dual system and are not registered in the packaging register of the central body.
► Offer reusable alternatives: For final distributors/fillers of single-use plastic containers with food or single-use beverage cups (e.g. restaurant, café, bistro), there is an obligation to offer a reusable alternative for single-use plastic food packaging and single-use beverage cups from 1 January 2023. Small businesses with a sales area of up to 80 m² and a maximum of five employees (e.g. snack bars, late-night shops, kiosks, but no branches) are exempt from this regulation. These do not have to offer reusable alternatives, but can instead also offer their customers to fill the containers they bring with them, if this is desired.
No declaration of completeness for small quantities of packaging
However, a special feature applies to smaller companies: Up to certain quantities, first-time distributors do not have to submit a declaration of completeness to the Central Agency. This exception applies if the quantity of packaging subject to system participation placed on the market in the previous year remains below the following thresholds:
▶ Glass: ≥ 80 tons per year
▶ Paper: ≥ 50 tons per year
▶ Leight-weight-packaging: ≥ 30 tons per year
Below these so-called "de minimis" limits, declarations of completeness are only to be submitted at the request of the central office or the competent Land authority.
To-do list for manufacturers
With BellandVision, you can meet the requirements of the Packaging Act quickly and with ease.
These are your next steps:
Quick check:
Find out whether your packaging is subject to system participation at www.verpackungsregister.org.
Registration:
If there is an obligation to participate your packaging in a dual system, register online with the Central Agency (“ZSVR”). Please note: Independent of the system participation obligation, all manufacturers of packaged products must register with the central body from 1 July 2022.
Licensing with BellandDual:
With our licence calculator or after a personal telephone conversation, you can quickly and easy participate your packaging in the largest dual system in Germany.
Data volume report:
Report your packaging quantities subject to system participation to the Central Agency and to us as your dual system.
Statement of Completeness („Vollständigkeitserklärung“):
If the de minimis limits are exceeded, you must also submit a declaration of completeness - we will be happy to advise you on this!
Any questions? You can find all answers from A for additional information about the declaration of completeness to Z for Zentrale Stelle ("Central Agency") in our FAQs. Or ready for the licensing of packaging? Then simply license online right away.