Changes to the Packaging Act: New obligations for publishers and bookstores from July 1, 2022

• Distributors of packaging filled with goods are obliged to register it in the LUCID packaging register. The registration obligation no longer only applies to packaging subject to system participation, but to all types of packaging (e.g. transport materials, reusable packaging).
  

• Ban on the distribution of packaged goods if the distributor has not complied with his obligation to register and, where applicable, to participate in the system. This distribution ban also extends to subsequent distributors.
  

• Final distributors of service packaging (e.g. paper bags, wrapping paper) are also required to report their data to LUCID. In certain cases, there is an obligation to contribute to the disposal costs for packaging subject to the system.
  

• From July 1, 2022, fulfillment service providers may only provide their services to companies that have fulfilled their obligation to register and participate in the system.

1) Registration in the LUCID packaging register

From July 1, 2022, publishers must register with the LUCID Packaging Register for all packaging placed on the market, including non-system-participating packaging, such as transport and reusable packaging). If you have already registered with the Central Agency for Packaging Registers (ZSVR), you can add further packaging to your details as part of a "change registration".

The obligation to register also applies if you have commissioned a service provider to deliver the goods.

2) Notification to dual system / contract with a system operator

Packaging subject to system participation requires further registration with a system operator, where you pay a disposal fee depending on the material and quantity. This includes, for example, shipping and secondary packaging. With the help of the ZSVR's quick check, you can find out in just a few minutes whether the packaging you have placed on the market is subject to system participation.

To register, you must conclude a contract with a system operator. You can find an overview of all systems here.

If you do not comply with your registration obligation and/or system participation obligation, your packaged goods will be subject to a distribution ban and fines may be imposed.

This also extends to subsequent distributors and fulfillment service providers and thus to us as your sales partner. We therefore require proof of registration and system participation from you.

1) Registration in the LUCID packaging register

If you pack goods for private end customers as a bookshop - in so-called service packaging such as a shipping bag, carrier bag or in wrapping paper - the registration obligation applies. You must register with the Central Agency for Packaging Registers (ZSVR) by July 1, 2022. This also applies if you already use system-participating service packaging, i.e. service packaging that has already been registered with a dual system by a pre-distributor.

However, there is no obligation to register if no shipping takes place and bags and gift packaging are not used at all.

2) Notification to dual system / contract with a system operator

Service packaging usually ends up in customers' waste and must therefore be reported to a dual system provider.

For the notification, you conclude a paid contract with a system operator, who in turn passes on the amount of packaging waste you expect to generate to the ZSVR. You must pay a share of the disposal costs in accordance with your share.

However, you can impose the system participation obligation (unlike the registration obligation) on the upstream distributor of the service packaging by using service packaging that is already licensed or system-participating. In this case, as part of your registration - see 1) above - you declare that you are already using or placing on the market system-participating packaging.