Duales System Deutschland (DSD)
Veolia Umweltservice Dual GmbH
Recycling Kontor Dual (RKD)
Zentek GmbH & Co. KG
RIGK GmbH (with focus on T&I)
Trade & Industry
Final distributors (but also Manufacturers and upstream distributors) of packaged goods not destined for the "private final consumer" (= Primary commercial packaging).
Producers and distributors of transport packaging (secondary and tertiary industrial packaging)
Producers and distributors who put into circulation for the first time “sales packaging filled with product” (Primary household packaging), typically destined for the "private final consumer" (households and comparable places such as restaurants, offices, hospitals, public venues etc.). This includes service packaging.
Trade & Industry
Industrial Sales packaging: Packaging made available as a sales unit not destined for the "private final consumer".
Transport packaging: Packaging that facilitates the transport of goods, or opened by the distributor (= grouped/secondary and tertiary industrial packaging)
Sales packaging: Packaging made available as a sales unit typically destined for the "private final consumer" and opened by the final consumer (incl. service packaging).
HH packaging includes secondary packaging which is defined as packaging that is used as packaging additional to sales packaging and is not necessary for transfer to the final consumer for reasons of hygiene, durability or the protection of goods from damage or contamination (similar to multipack, …).
All material (mainly glass, plastic, paper/cardboard, tinplate, aluminium, wood and composites)
Overall recycling target: 55 % - Overall recovery target: 60%
Additional recycling targets for HH packaging: Glass 75 %, Tinplate 70 %, Aluminium 60 %, Paper/cardboard 70 %, Plastics 36%, Composites 60 %, and wood 15% recycling.
Additional recovery targets for HH plastics packaging: 60% recovery.
At the moment no recycling targets for industrial sales packaging
Trade & Industry
DSD has licenced the Green Dot logo as trademark and licences the use of it.
Companies contracting with a competitor organization can obtain a licence from DSD for use of the Green Dot.
At RIGK the Logo is mandatory
Part Legislation and specific items
The first German Packaging Ordinance came into force on June 12, 1991. The objective of the ordinance is to avoid or reduce the impact of waste from packaging on the environment and to make a contribution towards protecting natural resources. Since 1991, some amendments have been adopted so that the system was further improved.
If a company trades sales packaging filled with goods which are normally purchased by "private final consumers" (i.e. households and similar sites, e.g. restaurants, hospitals, offices, public venues etc.), this company is obliged to participate in a dual system (cfr. accredited organisation) or a branch solution for the disposal of such packaging to ensure the collection of such sales packaging on a full-coverage basis. Only distributors of “service packaging” filled with goods receive the right to delegate this obligation to manufacturers or prior distributors of the service packaging.
There are 10 dual systems officially recognised in all 16 German Federal States. They are listed with their contact data: www.ihk-ve-register.de/inhalt/duale_systeme
There are some exemptions with regard to the mandatory participation in a dual system. The Packaging Ordinance allows for instance, producers and distributors supplying packaged products to business sites where waste generated are similar to household waste (hotels, canteens, hospitals, ..) to appropriately dispose and recover this packaging waste themselves1 or through a third party via a suitable solution (cfr. branch-related solutions). The scope of such exceptions has been significantly reduced through the 7th amendment of the Packaging Ordinance of 2014, however.
Separate treatments are defined in the Packaging Ordinance for refillable packaging and disposable drinks packaging subject to a deposit. An obligation to participate in a recognised dual disposal system or in a branch solution does not exist for this packaging. Distributors who put drinks (beer and mixed drinks containing beer, water, soft drinks carbonated and non-carbonated and mixed alcoholic drinks) into circulation in one-way drinks packaging with a filling volume of between 0.1 and 3 litres shall be obligated to charge the purchaser a deposit of at least 25 Euro cents including value-added tax per drinks pack. The deposit shall be charged by each further distributor at each distribution level until transfer to the final consumer. Deutsche Pfandsystem GmbH (www.dpg-pfandsystem.de) prepares the organizational and legal framework for the collection and deposit clearing of compulsory-deposit one-way drinks packaging.
From the German point of view, the distributor who imports product and therefore the party responsible for packaging is not necessarily the German company buying a product from a foreign company. It can also be the foreign company that exports the product to Germany. The party responsible is the first initiator setting packaged goods on the German market. The responsibility will depend on the contract between the importer and the exporter.
For sales packaging arising at the "private final consumer", there is an obligation to submit a “completeness statement” to the Association of German Chambers of Commerce and Industry (DIHK - www.dihk.de) when a company exceeds at least one of the following volume thresholds for packaging put on the German market : 80 T glass packaging, 50 T paper/cardboard packaging or 30 T aluminium, tin foil, plastics and composites packaging. This certificate has to be checked by an external party (auditor, tax consultant) and submitted by 1 May every year to cover the previous year. Companies which only market T&I packaged goods don’t have this obligation of declaration.
Transport, grouped/secondary packaging and sales packaging for commercial end consumers (T&I)
For transport packaging, secondary packaging and sales packaging which ends up at commercial end consumers sites, the participation in a “recognised dual disposal system” is not possible and is also not necessary. Take-back and recycling of this packaging are to be organised rather by the parties responsible for packaging themselves. Basically, for all this commercial packaging, it applies that the supplier of the packaged goods is obligated to take back the empty packaging. The Ordinance, however, allows explicitly that the participants can arrange divergent agreements (e. g. that the customer organises disposal him/herself and the supplier reimburses this or the assigning of an external service provider).
Voluntary initiatives have been developed for transport, secondary packaging and sales packaging for commercial end consumers:
RIGK GmbH offers innovative recovery systems and recycling solutions for T&I plastic packaging. Within the RIGK system, the packers/fillers or importers contribute to the system.
KBS: Collection system for the return of used T&I metal packaging. Within the KBS system, the packers/fillers or importers contribute to the system.
REPASACK GmbH is specialised in the take-back and recycling of used paper bags from T&I. Distributor of paper bags can satisfy their statutory requirements through a participation in the Repasack system. The packaging manufacturers or distributors/importers have to contribute to the system. Packers/fillers can also contribute and oblige their bag manufacturer to use the appropriate Repasack logo on the packaging they manufacture for them.
RESY guarantees the complete disposal and reuse of all transport and grouped packaging bearing the RESY symbol. The legal use of the RESY symbol means that all the specifications of the Packaging Directive for transport packaging have been fulfilled. Only recyclable paper and cardboard transport and grouped packaging are allowed to carry the RESY symbol. To use the RESY symbol on packaging that you introduce to the market you first have to conclude a contract. Within Resy system, the packaging manufacturers or distributors/importers contribute to the system.
1 Stronger rules from October 2014
Dual System (mainly packaging for households and small commercial sites)
- To take over the responsibilities of their members
- To collect the licence fees from parties responsible
- To reach the recovery and recycling targets for its members
- To report its results regarding recovery and recycling, to the authorities
- To organize the collection, sorting and recycling of packaging waste in Germany with the support of waste management partners.
- To finance the full cost of collection, sorting and recycling of HH packaging waste
- To stimulate the selective collection and recycling of HH packaging waste through communication campaigns towards consumers (B2C).
Voluntary systems (mainly packaging in the T&I sector)
- To take over the responsibilities of their members
- To collect the contribution from parties responsible
- To report its results regarding recovery and recycling, to the authorities if required