Non-compliance with the German Packaging Act (VerpackG) triggers severe penalties. Authorities can levy fines of up to €200,000 for failing to participate in a dual system for recycling. Even simple registration failures can cost up to €100,000 per case.

Beyond fines, you face an immediate prohibition on sales, effectively blocking your access to the German market. Online marketplaces are legally required to verify your compliance and will delist non-compliant sellers. The public nature of the LUCID register means competitors can easily identify and report non-compliant businesses. You must take action now to protect your revenue and market presence. This regulation establishes a clear framework of accountability for all distributors.

To legally sell to German consumers, you must complete three core obligations under the VerpackG. These steps are mandatory for every business, regardless of size or sales volume. There are no minimum quantities; the law applies from the very first item you ship.

Here are the required actions:

1. Register with the LUCID Packaging Register: Before placing any goods on the market, you must register your company with the ZSVR (Central Agency Packaging Register). This process is free and results in your unique EPR number.
2. Participate in a Dual System: You must sign a licensing contract with a state-approved recycling company (a ‘dual system’). This fee covers the cost of collecting and recycling your packaging materials.
3. Report Your Packaging Volumes: You are required to report the volume and material types of your packaging to both your chosen dual system and the LUCID register.

Completing these steps is not a one-time task but an ongoing obligation. A checklist for VerpackG compliance can help manage these duties. The next section clarifies exactly who is responsible for these tasks.

The VerpackG applies to any company that is the first to place packaged goods on the German market for private consumers. This ‘producer’ definition is broad and includes nearly all B2C sellers. If you ship to Germany, you are almost certainly affected.

This includes the following business types:

• Online retailers shipping goods to German end-users.
• Foreign companies exporting to Germany.
• Importers who are the first distributor within Germany.
• Manufacturers selling directly to German consumers.

The responsibility lies with the entity legally responsible for the goods as they cross the German border. For most online sellers, this means you are directly obligated. You cannot assume a fulfillment partner is handling this. To understand your specific duties, review our guide on compliance for small online shops. This legal framework ensures every market participant contributes to recycling efforts.

Every component of your packaging must be licensed, with no exceptions for material type. This includes cardboard boxes, plastic films, glass jars, adhesive tape, and even filler materials like bubble wrap. The law covers all sales packaging that typically ends up as waste with the consumer.

The licensing fees you pay to a dual system are calculated based on two factors: the material type and its total weight in kilograms. This system creates a direct financial incentive to reduce packaging and use materials that are easier to recycle. Using lighter, mono-material packaging can lower your annual compliance costs by over 15%. You must accurately forecast and report these volumes annually. Learn how to license shipping boxes to ensure your calculations are correct. This system transitions the financial burden of waste management to the producers.

While Germany’s VerpackG is strict, it is part of a larger European movement. The new EU Packaging and Packaging Waste Regulation (PPWR) will soon enforce harmonized rules across all member states. By 2030, all packaging placed on the EU market must be recyclable.

The PPWR introduces several new requirements that will impact B2C sellers. These include mandatory reuse targets for e-commerce packaging and standardized EU-wide labeling to help consumers with sorting. This means a compliance strategy focused only on Germany is shortsighted. Businesses need a pan-European approach to remain competitive. A full EPR compliance solution is vital for future market access. These regulations signal a major shift toward a circular economy across the continent.

The complexity of packaging regulations in Germany and across the EU creates a significant administrative burden. Managing registrations, licensing, and reporting for multiple countries requires constant attention and expertise. Failure to comply puts your entire European operation at risk.

Partnering with Deutsche Recycling ensures you are 100% compliant, letting you focus on your business. We handle the entire process for you:

• We manage your registration in the LUCID portal.
• We secure your packaging license with a dual system.
• We handle all necessary data reporting accurately and on time.
• We provide a single point of contact for all your EPR obligations.

You must act now to comply with these EU directives. Do not wait for a warning letter or a sales ban. Contact Deutsche Recycling for a consultation and let our experts ensure your packaging is compliant for B2C sales across Europe.