Packaging Act (VerpackG): Compliance guide for manufacturers and retailers
The Packaging Act (VerpackG) 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 VerpackG is a German law and applies to all companies that place goods in packaging on the German market.
Which packaging is affected?
In principle, all packaging placed on the market in Germany is subject to the Packaging Act. A distinction is made according to the type of use and the place of origin:
- 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 for purely commercial use (B2B).
- Material fractions: Classification is based on material type, such as paper/cardboard/cardboard (PPK), plastics, glass, ferrous metals, aluminum, or composite materials.
- Special case of beverages: Specific deposit and return regulations often apply to beverage packaging.
Who is responsible?
The responsibility lies with the so-called first distributor. These are:
- Producers and online retailers who package and ship goods for the first time.
- Importers who import goods from abroad to Germany that are already packaged.
- Retailers (subsequent distributors) who must ensure that their upstream suppliers are properly registered.
Important: Since July 2022, an extended registration requirement has applied to all packaging filled with goods. Manufacturers not based in Germany also have the option of appointing an authorized representative to handle their obligations.
The main responsibilities: registration and system participation
In order to comply with the law, initial distributors must follow three essential steps:
LUCID registration: Registration with the Central Agency Packaging Register (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.
Information obligation: End consumers must be informed about return options, especially for reusable systems.
Risks of non-compliance: fines and sales bans
Violations of the Packaging Act are consistently prosecuted in Germany. Companies risk:
- High fines: Administrative penalties of up to EUR 200,000.
- Profit skimming: Confiscation of revenues generated through non-compliance.
- Risk of warnings: Civil lawsuits and expensive warnings from competitors.
- Automatic sales ban: Without a valid LUCID number, there is a legal sales ban – online marketplaces immediately block retailers who fail to provide proof.
Our service
With ECOPV-EU, you receive our exclusive service for compliance with the legal requirements of the Packaging Act. This includes support with the mandatory registration with the Central Agency Packaging Register (ZSVR) as well as the licensing of your packaging with one of the dual systems. We will handle the transmission of your reports for you. All we need are your quantities and your trust.
Specific requirements for manufacturers according to VerpackG
System participation
Producer must participate in a dual system or submit a declaration of completeness.
Licensing In A Dual System
The producer (the first to place a product with packaging on the German market) pays a recycling fee for its packaging in return for a licence and finances the recycling of the packaging.
Quantity reports
Monthly, quarterly or annual reporting of packaging quantities placed on the market to the dual system.
Recyclability
Packaging must meet minimum requirements for recyclability.
The Packaging Act (VerpackG)
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FAQs
Where do I have to register?
In addition to participating in a dual system, companies must also be registered with the Central Agency Packaging Register (ZSVR). This acts as a supervisory authority for compliance with legal obligations.
What is a LUCID number?
The LUCID number is the registration number at the Central Agency Packaging Register (ZSVR). In Germany, all distributors of packaging are obliged to register with the ZSVR. In addition, marketplaces such as Amazon or Ebay must request the LUCID numbers of their retailers.
When do I have to license my packaging?
In principle, all sales packaging that accumulates as waste with the end consumer, i.e. B2C packaging filled with goods, must be licensed. This also includes shipping material and packaging from the food service industry. Packaging from the food service industry is classed as service packaging.
Who is the distributor of packaging?
A producer with a registration obligation is a party that provides packaging containing goods to a third party/end customer for the first time, with or without charge, for the purpose of sale, consumption or use. And these packages usually accumulate as waste at the end consumer.
Who is affected by the Packaging regulations?
The obligation to register affects all packaging producer, regardless of the type of packaging they are filling for retailers in Germany for the first time. Electronic marketplaces and fulfillment service providers take on new responsibilities.
Which packaging is subject to registration?
Whether plastic film, cardboard boxes or glass bottles: all packaging that typically accumulates with the private end consumer and is therefore considered sales packaging must be licensed in accordance with the German Packaging Act (VerpackG).
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