As before, manufacturers of packaging that typically end up with private consumers (packagings requiring packaging) are required to participate in at least one dual system with their products. This ensures that packaging is collected and recycled. Re-packaging products also will be subject to participation in the dual system in the future if they are ultimately end up with the consumer. For packaging that is not typically for the consumer but for transport, separate returns arrangements still apply.
On the other hand, the obligation from 01.01.2019 onwards is that manufacturers of packaging subject to the new system must register their packaging at ZSVR, otherwise the packaging may no longer be used in Germany after 01.01.2019. The ZSVR has already started operations and registration has been possible since the end of August 2018.