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Article type within the meaning of the VerpackG (AT and DE)?

Most of the items we supply are empty packaging products that only become typical sales packaging once they are filled by you as the packer.

According to the Packaging Act (VerpackG), the first placer on the market – in this case, you as the packer – is responsible for the proper licensing of these sales packaging items.

Our products are generally not intended to be service packaging. If you plan to use a packaging item as a service packaging on an exceptional basis, please inform us before purchasing, so that we can arrange for the necessary licensing.

Please note that any related licensing costs will be charged to you, as our product prices do not include or account for such costs.

Sales packaging and service packaging are often confused in everyday life – but legally, the difference is crucial. The following overview explains in simple terms who is responsible for licensing in Germany and Austria and when a package is considered sales packaging or service packaging.

Sales packaging vs. Service packaging – Comparison between Germany and Austria

Criterion Germany (VerpackG) Austria (Packaging Ordinance & AWG) Examples
What is sales packaging? Sales packaging is filled by the manufacturer or packer with goods and reaches the end customer as a sales unit. Sales packaging is filled by the packer or producer and intended for distribution. Yogurt cup, tin can, mayonnaise bucket, delicatessen cup
What is service packaging? Service packaging is filled only at the point of sale for the end customer – e.g., in cafés, snack bars, or butcher shops. Service packaging is filled directly when handed over to the end customer. In Austria, the licensing must be carried out by the packaging supplier. Coffee-to-go cup, bakery bag, fries tray, pizza box
Who has to license it? Sales packaging: the packer or first distributor.
Service packaging: the retailer or food outlet that fills it and gives it to the end customer.
Pre-licensing by the supplier is possible but must be proven.		 Sales packaging: the packer or importer.
Service packaging: the supplier or manufacturer is legally obliged to place it on the market already licensed.		 Filling plant licenses bucket → Sales packaging
Bakery bag licensed by supplier → Service packaging
When does the packaging occur? Already at purchase in retail – the product is pre-packed. At the packer or seller when the packaging is filled for the first time. Yogurt cup in the supermarket vs. coffee cup at the bakery
Our products We generally supply empty packaging that becomes sales packaging only after being filled by the customer. It must be licensed by the packer (you as the customer). In Austria, we also supply empty packaging. Only if you wish to use it exceptionally as service packaging must you inform us before purchase so we can handle the licensing. The corresponding costs will be charged to you. Buckets, cups, lids, films – standard: sales packaging
Proof & documentation Registration required with LUCID and proof of system participation (VerpackG §§ 7–10). Contract with an Austrian collection and recovery system (e.g., ARA, Reclay) required; proof of quantity reporting (§ 13g AWG). System confirmation, invoice or contract proof

Summary

In Germany, the party who fills the packaging and hands it to the end consumer must license it (for service packaging). In Austria, however, the obligation for service packaging lies with the packaging supplier.

Our products are generally empty packaging that only become sales packaging after being filled by the customer. Only in the case of explicit use as service packaging do we handle licensing at cost.

Status: 2025 · Sources: BMUV, Central Packaging Register (LUCID), BMK, ARA, Reclay · All information without guarantee.