You are considered a manufacturer within the meaning of the Packaging Act if you:
- Fill packaging with goods
- For the first time
- In Germany
- Put into circulation
In the sense of the Packaging Act, a producer is basically a person who fills a packaging with goods for the first time. This can be producers of products who pack them after manufacture, but also trading companies who sell own brands and hand over the filling to a third party. Importers are also considered manufacturers if they bear the legal responsibility for the goods when they cross the border. In addition, all mail-order and online traders who fill a shipping package with goods are considered manufacturers within the meaning of the Packaging Act. Incidentally, the German Packaging Act also applies to foreign traders who ship to Germany.
If this definition of manufacturer applies to you, you must in any case comply with the registration obligation and register in the LUCID register. What other obligations you have depends on the specific types of packaging you put into circulation.