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Licensing of Transport and Secondary Packaging

Germany and Austria have clear legal requirements for the collection, recovery and proper disposal of packaging used in B2B supply chains. In Germany, a distinction is made between transport packaging, secondary packaging, and shipping packaging.

Secondary and shipping packaging (e.g. shipping boxes, labels or filling materials) that end up as waste at our customers’ sites are subject to system participation. This obligation is fulfilled through our licensing agreement with Interzero Deutschland GmbH (Manufacturer No. 235440, Contract No. DSIV-10001302).

Transport packaging (e.g. pallets, interlayers or stretch films) used exclusively for transport between commercial entities is not subject to system participation, but is covered by the take-back obligation under § 15 VerpackG, which we fully comply with.

In Austria, all transport and secondary packaging placed on the market is properly licensed under the Packaging Ordinance (VerpackVO) and the Waste Management Act (AWG) through Interzero Circular Solutions Austria GmbH (License No. SIA 152983).

This ensures that all packaging materials we use – in both Austria and Germany – are collected, recovered and recycled in full compliance with national legislation.

Types of Packaging & Obligations – Germany vs Austria

Status: 2025 | Sources: VerpackG (DE), Packaging Ordinance & AWG (AT), Interzero, UBA, BMK

Type of Packaging Germany (VerpackG) Austria (Packaging Ordinance & AWG) Legal Basis
Sales Packaging
(End Consumer Packaging)		 Packaging filled with goods that ends up with the end consumer. Mandatory system participation via a dual system (e.g. Interzero, Grüner Punkt). Packaging filled with goods that ends up with private or equivalent end consumers. Licensing through a collection and recovery system (e.g. ARA, Interzero Austria). DE: §7 VerpackG
AT: §13g AWG, §3 Packaging Ordinance
Grouped / Shipping Packaging
(e.g. cartons, labels, filling material)		 Subject to system participation (§7 VerpackG), as it becomes waste for the customer. Subject to licensing through an approved collection and recovery system (e.g. ARA or Interzero Austria). Applies to all packaging that remains with the customer. DE: §7 VerpackG
AT: §13g AWG, §4 Packaging Ordinance
Transport Packaging
(e.g. pallets, interlayers, stretch film)		 Not subject to system participation, but take-back obligation under §15 VerpackG. Return must be offered free of charge. Take-back and recycling obligation under §13h AWG. Licensing via collection systems possible but not mandatory. DE: §15 VerpackG
AT: §13h AWG
Service Packaging
(e.g. cups, carrier bags, to-go packaging)		 Subject to system participation. The obligation may be delegated to the upstream distributor – only if they are registered in Germany in the LUCID register and participate in a dual system (“pre-participated licensing”). Foreign suppliers without German registration cannot assume the system participation. Subject to licensing in Austria. Delegation (upstream fulfillment) to an Austrian system participant is possible (national AT model). Cross-border pre-licensing for Germany is not covered by this. DE: §7 (2) VerpackG
AT: §13g (4) AWG
Obligations for Online Retailers Applies only to retailers who send filled packaging to end consumers. Retailers of empty packaging are not affected. Also applies only to filled packaging. Retailers of empty packaging are not subject to system participation. DE: §7 VerpackG
AT: §13g AWG
Documentation & Proof Registration in LUCID, proof of system participation, retention period of three years. Contract with a collection system, retention period of seven years. Proof must be provided upon request. DE: §9, §10 VerpackG
AT: §22 AWG
Penalties for Non-Compliance Fines up to €200,000, sales ban in case of missing registration. Administrative penalties up to €37,000, sales ban in case of non-reporting. DE: §34 VerpackG
AT: §79 AWG

Note: Both countries follow the principle of product responsibility – whoever first places packaging on the market is also responsible for its take-back and recycling.

Disclaimer: This information has been prepared with the greatest care but serves solely for general guidance. We accept no liability for completeness or accuracy. All companies are obliged to verify their own obligations independently.