Service packaging is packaging that is filled with goods at the point of supply by the retailer (e.g., carrier bags, disposable salad bowls, paper bags for chips). Here the final distributor (Section 3(13) of the Packaging Act) may require that the system inclusion is inherited from the upstream distribution stage (Section 7(2) of the Packaging Act). All other obligations (e.g., registration under Section 9 of the Packaging Act) and potentially the submission of a declaration of completeness under Section 11 of the Packaging Act, are correspondingly also transferred to the upstream distributor. Final distributors, who supply the end consumer, are in this regard not subject to any further obligations under the Packaging Act (final clause of Section 7(2) of the Packaging Act).
If, however, the final distributor brings as service packaging any other packaging onto the market for the first time, and the upstream distributor has already assumed the legal obligations for this packaging, no exemption from the obligation to register or from all other legal obligations will apply.