Many pharmacies use service packaging on a daily basis to simplify the handover of products to customers. Service packaging is characterised by the fact that it is only filled when it is handed over to the customer - typically at the point of sale. Service packaging includes, for example, paper bags and packaging materials that are used for the production of formulations and preparations. The special feature is that service packaging is the only type of packaging that may be purchased pre-licensed.
Caution: The packaging must be expressly identified as pre-licensed packaging by the packaging distributor, because not all service packaging is already licensed by the distributor.
Your obligations are derived from whether you acquire service packagings pre-licensed or not pre-licensed:
You only use pre-licensed service packaging: Since 01 July 2022, you must comply with a registration obligation. Since this date, companies that use pre-licensed service packaging must also register as distributors of this packaging. The registration must take place in the LUCID register. This is the register of the Central Agency Packaging Register, which is the control body behind the Packaging Act.
You also or exclusively use non-pre-licensed service packaging: Then you must become active immediately. As a distributor of packaging that is disposed of in the household waste of private end consumers, you must then fulfil all three obligations of the Packaging Act yourself before you put this packaging into circulation. In addition to the obligation to register with the Central Agency Packaging Register, it is also mandatory to participate in a dual system by means of a licence agreement. The dual system takes over the collection, sorting and recycling of the packaging you put into circulation. With the help of the Lizenzero calculator, you can quickly and easily comply with your system participation obligation.
For a detailed explanation, also read our blog post The Packaging Act for Pharmacies: What You Must Consider Before Selling