Packaging Ordinance and Waste Disposal System
The Packaging Ordinance was created to ensure environmentally friendly disposal of packaging materials throughout Germany. The 5th revision came into force on 1 January 2009.
Since that date manufacturers and retailers have been obligated to take part in a gapless waste disposal system to ensure recovery of their packaging products.
The obligations in the Packaging Ordinance apply to all manufacturers and distributors who are the first sellers of industrially filled packaging typically used by private end consumers (§ 6 I VerpackV).
The STI Group as packaging manufacturer is not responsible for this service because lawmakers have specifically denoted the initial company putting "sales packaging filled with merchandise" on the market as subject to the participatory and declaration obligations. Their reasoning: only the seller – and not the manufacturer of the packaging – knows which packaging in which sizes and quantities are being sent into the zone subject to the Packaging Ordinance, i.e. requiring licensing under the Dual System. The 'first sellers' obligated to participate in the system must produce a letter of representation that allows the ordinance issuers and enforcement authorities to monitor adherence.
In situations where the STI Group agrees to arrange licensing, the documentation of quantity flow must first be reviewed by a financial auditor, tax consultant, chartered accountant or independent expert, followed by the submission of a letter of representation to the local Chamber of Commerce and Industry.