Imported packaging must also be licensed in Germany, because the packaging accumulates in Germany at the private end consumer. The company that imports the corresponding packaging commercially into Germany is subject to licensing. As a rule, this is the importer (i.e. the person who actively brings the goods into the FRG or arranges for this to happen).
If a foreign seller or shop operator sells directly to customers in the FRG without using an intermediary, he is himself an obligated party in the sense of the Packaging Act. No distinction is made between imports from EU and non-EU countries.
The Packaging Act (VerpackG) only applies to products sold in Germany. If you ship products abroad, packaging for these products is not affected by the German Packaging Act and therefore does not have to be licensed with a dual system in Germany. However, as a manufacturer and distributor, in this case you must prove beyond doubt that the packaging is not circulated in Germany. According to the Packaging Act, it must be evident from the design of the packaging or corresponding accompanying documents that the packaging in question is intended exclusively for export when it is first placed on the market. Furthermore, the system participation must be made up for immediately if the packaging is nevertheless delivered to the end consumer within the scope of application of the VerpackG contrary to its original intended use.
Please note: In the meantime, many importing countries have also introduced laws for the disposal and recycling of packaging materials.