What the Packaging Act covers
VerpackG applies to anyone who first places filled packaging on the German market—whether you manufacture in the EU, import from abroad, or sell via online marketplaces.
- B2C packaging (typical consumer waste) must be licensed with a dual system.
- B2B transport packaging (ending up at business users) usually isn’t licensed with a dual system, but still has take-back and documentation duties.
- The law is material-agnostic: paper/cardboard, plastics, glass, aluminum, steel, composites—all count.
LUCID registry: your first mandatory step
LUCID is the national producer register maintained by the Zentrale Stelle Verpackungsregister (Central Packaging Register). Registration is mandatory before sales. You’ll receive a LUCID registration number that marketplaces often require. Key data you provide: company details, brand names, and contact info. Expect to keep these details updated.
Common mistakes to avoid
- Registering after sales start
- Using a marketplace VAT or tax ID instead of your legal entity data
Dual system licensing: financing collection & recycling
For retail (B2C) packaging, you must license packaging volumes with a dual system (private compliance schemes). You pay fees based on material type and kilograms placed on the market. Eco-modulated fees may reward recyclable designs (e.g., mono-materials, no carbon black). Contract first—then report those licensed volumes in LUCID to match what you declare to the system.
Budget tip: start with conservative volume forecasts to avoid large true-ups later, then adjust as your sales data stabilizes.
Reporting calendar & ongoing compliance
Expect three reporting rhythms:
- Initial forecast (when you sign with a system)
- Ongoing updates (if your volumes change)
- Annual declaration: prior-year actuals by material and kilograms—filed both to your dual system and mirrored in LUCID so the numbers match (“Datenharmonisierung”).
Larger producers may need an audited declaration of completeness via a certified auditor if thresholds are exceeded. Even if you’re small, keep accurate, source-backed records.
FAQ quick answers
Do I need to register if I only sell small quantities?
Yes, if you’re the initial distributor for B2C packaging.
Can my 3PL handle this for me?
They can help with data, but legal responsibility remains with you.
What if I use only recyclable materials?
Great for the environment—and may lower fees—but licensing and reporting still apply.
I sell only to businesses. Am I exempt?
Likely no system participation, but you still have take-back and record-keeping duties.
What happens if I don’t comply?
Potential fines, marketplace delisting, and public non-compliance visibility.
Treat VerpackG like a standard launch checklist item—alongside VAT, labeling, and product safety. Get your LUCID registration, pick a dual system, and set up a repeatable reporting process. Do this early, keep your data tidy, and you’ll stay compliant while unlocking Germany’s sizable market with confidence.
