Packaging Act (VerpackDG): Compliance Guide for Manufacturers and Retailers
The Packaging Act (VerpackDG) regulates the placing on the market, take-back, and high-quality recycling of packaging waste in Germany. As a central pillar of the circular economy, it transposes the EU Waste Framework Directive and the Single-Use Plastics Directive into national law.
Important: The VerpackDG is a German law and applies to all companies that place goods in packaging on the German market.
Scope: Which products are affected?
In general, all packaging placed on the market in Germany is subject to the Packaging Act. A distinction is made based on the type of use and the location where the packaging is generated:
- Types of packaging: sales packaging, outer packaging, service packaging, shipping packaging, and transport packaging.
- B2C vs. B2B: A distinction is made between packaging subject to system participation, which typically ends up with private end consumers (B2C), and packaging intended solely for commercial use (B2B).
- Material categories: Classification is based on material type, such as paper/cardboard (PPK), plastics, glass, ferrous metals, aluminum, or composites.
- Special case: Beverages: Specific deposit and return regulations often apply to beverage packaging.
Who is responsible?
The responsibility lies with the so-called “first distributor.” These include:
- Manufacturers and online retailers who package and ship goods for the first time.
- Importers who bring pre-packaged goods into Germany from abroad.
- Retailers (subsequent distributors) who must ensure that their upstream suppliers are properly registered.
Important: Since July 2022, an expanded registration requirement has been in effect for all packaging containing goods. Manufacturers not based in Germany also have the option of appointing an authorized representative to handle these obligations.
The key obligations under the Packaging Act
To comply with the law, first-time distributors must follow three essential steps:
- LUCID Registration: Registration with the Central Packaging Register Foundation (ZSVR) is mandatory before goods are placed on the market.
- System Participation (Licensing): For B2C packaging, a contract must be concluded with a dual system for nationwide collection and recycling.
- Data reporting: The annual quantities of packaging placed on the market must be reported identically to both the dual system and the LUCID packaging register.
- Duty to inform: End consumers must be informed about return options, particularly in the case of reusable systems.
Risks Associated with Violations and Non-Compliance
Violations of the Packaging Act are rigorously enforced in Germany. Companies risk:
Heavy fines: Administrative penalties of up to 200,000 EUR.
Profit forfeiture: Confiscation of revenue generated through non-compliance.
Risk of legal action: Civil lawsuits and costly cease-and-desist letters from competitors.
Automatic sales ban: Without a valid LUCID number, there is a legal ban on sales – online marketplaces immediately suspend merchants if proof is lacking.
[NEW EU REGULATION] From the Packaging Act to the PPWR
The German Packaging Act (VerpackG) currently serves as the legal basis, but is being gradually supplemented and harmonized by the new EU Packaging Regulation.
Prepare your company for the new requirements well in advance.
Learn everything you need to know about design for recycling, recycled content targets, and the EU-wide labeling requirement.
Our Service
With ECOPV-EU, you receive our exclusive service to ensure compliance with the legal requirements under the Packaging Act (VerpackDG).
This includes assistance with the mandatory registration with the Central Packaging Register (ZSVR) as well as the licensing of your packaging with one of the dual systems. We will handle the submission of your reports on your behalf. All we need from you are your volume figures and your trust.
Specific requirements for manufacturers under the Packaging Act
System participation
Manufacturers must participate in a dual system or submit a declaration of compliance.
Licensing
Manufacturers pay licensing fees for their packaging to help fund the waste management infrastructure.
Quantity reports
Monthly, quarterly, or annual reporting of the quantities of packaging placed on the market to the dual system.
Recyclability
Packaging must meet minimum requirements for recyclability.
FAQ
Where do I need to register?
In addition to participating in a dual system, companies must also be registered with the Central Agency for Packaging Registration (ZSVR). This agency acts as a supervisory body to ensure compliance with legal obligations.
When do I need to obtain a license for my packaging?
In general, all sales packaging that becomes waste in the hands of the end consumer—that is, B2C packaging containing goods—must be licensed. This includes shipping materials as well as packaging from the food service industry. Packaging from the food service industry is classified as “service packaging.”
Who is affected by the Packaging Act?
The registration requirement applies to all packaging manufacturers, regardless of the type of packaging they fill for the first time in Germany for commercial purposes. Online marketplaces and fulfillment service providers are taking on new responsibilities.
What is a LUCID number?
The LUCID number is the registration number with the Central Agency for Packaging Registration (ZSVR). In Germany, all distributors of packaging are required to register with the ZSVR. In addition, marketplaces such as Amazon and eBay must request the LUCID numbers from their sellers.
Who is the distributor of packaging?
A responsible distributor (manufacturer) is any person who, for the first time, supplies packaging containing goods to third parties – whether for a fee or free of charge – with the intention of sale, consumption, or use, if such packaging typically becomes waste in the hands of end consumers.
Which types of packaging must be reported?
Whether it’s plastic film, cardboard boxes, or glass bottles: All packaging that typically accumulates in the homes of private consumers and is therefore considered sales packaging must be licensed under the Packaging Act (VerpackG).
The Packaging Act (VerpackG)
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