The German Packaging Act (VerpackG) applies to any company first placing packaged goods onto the German market that ultimately end up with the private consumer. This includes manufacturers, importers, and online sellers shipping products cross-border. There are no exceptions or minimum quantities; your obligations begin with the very first item you ship. The law holds the initial distributor responsible for financing the collection and recycling of their packaging materials. This framework is known as Extended Producer Responsibility (EPR). Fines for non-compliance can reach as high as €200,000 per case. The Central Agency Packaging Register (ZSVR) was established to oversee these regulations, ensuring transparency and enforcement. Understanding your specific duties is the first step toward securing your business operations in Germany. You can learn more about what is required for VerpackG compliance. The next step is to complete the mandatory registration process.

Before any of your products are sold in Germany, you must register with the LUCID packaging register, which is operated by the ZSVR. This registration is free of charge but is a non-negotiable legal prerequisite. During the process, you will provide your company details and list the brand names under which you sell your products. Upon completion, you receive a unique LUCID number. This number is your proof of registration and is required for all subsequent compliance steps, including contracting with a dual system. Marketplaces and fulfillment partners will demand this number, as they are now also held liable. You must complete these steps to get help with LUCID registration. Once registered, you must select a partner to handle the recycling of your packaging.

After registering in LUCID, you must license the packaging volumes you place on the German market with a state-approved dual system. These systems organize the nationwide collection, sorting, and recycling of packaging waste on behalf of producers. You pay a fee based on the material type and weight of your packaging. These fees directly fund the recycling process for materials like cardboard, plastic, and glass. There are over 10 dual system providers in Germany to choose from. You must have a valid license for the entire calendar year. To understand the German dual system is to understand how Germany finances its circular economy. With your packaging licensed, your next obligation is to report your data accurately.

Compliance with the German Packaging Act 2024 is an ongoing process that requires regular data reporting. Companies must submit two types of reports to the LUCID register. First, you must submit the same packaging volume data to LUCID that you reported to your dual system partner. Second, you may need to submit a Declaration of Completeness (Vollständigkeitserklärung) if you exceed certain volume thresholds—80,000 kg of glass, 50,000 kg of paper, or 30,000 kg of plastics, for instance. This declaration must be verified by a registered auditor. Here are the key data points you must track:

• Total weight of paper and cardboard
• Total weight of glass
• Total weight of plastics
• Total weight of ferrous metals (e.g., steel)
• Total weight of aluminum
• Total weight of beverage cartons
• Total weight of other composite packaging

Accurate reporting is critical, as discrepancies can trigger audits and penalties. You must declare packaging materials correctly to maintain compliance. These core duties form the foundation, but new regulations require further action.

The regulatory landscape continues to evolve, and 2024 brought significant changes you must address. As of January 1, 2024, the mandatory €0.25 deposit was extended to single-use plastic bottles containing milk-based drinks. Additionally, the Single-Use Plastics Fund Act (EWKFondsG) came into force, requiring producers of certain single-use plastic items to register on the DIVID platform by December 31, 2024, and pay into a fund. Looking ahead, further changes are already law. From January 1, 2025, all PET single-use beverage bottles must contain at least 25% recycled plastic (recyclate). This share increases to 30% for all single-use plastic bottles in 2030. Staying ahead of these deadlines is vital. A guide for international sellers can help navigate these complexities. The consequences of inaction are severe and can halt your German sales overnight.

The German authorities actively enforce the Packaging Act. Failure to comply is not a trivial offense and carries significant consequences. Companies without a valid LUCID registration or dual system license face an immediate ban on sales in Germany. Furthermore, financial penalties are steep, reaching up to €200,000 for failing to register or license packaging. Even minor violations, such as incorrect data reporting, can result in fines of up to €10,000. Online marketplaces like Amazon and eBay are now legally obligated to verify the compliance of their sellers and will block listings that lack a valid LUCID number. These platforms blocked thousands of non-compliant sellers in mid-2022. The risk of inaction is simply too high. To avoid EPR fines in Germany, you must take your obligations seriously. For complete peace of mind and guaranteed compliance, partnering with an expert is the most effective solution.

Navigating the complexities of the German Packaging Act 2024 requires expertise and constant vigilance. Deutsche Recycling offers a comprehensive EPR Full-Service solution that manages all your obligations. We handle your LUCID registration, secure the most cost-effective dual system license, and manage all your data reporting throughout the year. Our team of experts ensures you are always 100% compliant with all current and future regulations, including the new Single-Use Plastics Fund Act. By partnering with us, you eliminate the risk of fines and sales bans, freeing up your internal resources to focus on growing your business. Do not let complex regulations become a barrier to the German market. Take action today to secure your business. Contact Deutsche Recycling for a non-binding initial consultation and ensure your complete compliance.