The German Packaging Act (VerpackG) makes producers responsible for the entire lifecycle of their packaging. This law applies to every business, including cross-border e-commerce sellers, that sells to German consumers, with no exceptions for small quantities. Compliance involves three core duties: registering with the LUCID portal, joining a dual system for recycling, and reporting your packaging volumes. Failure to comply can result in fines of up to €200,000 for not participating in a recycling program and up to €100,000 for registration errors. From January 1, 2025, new rules also mandate that PET single-use beverage bottles contain at least 25% recycled plastic. You can comply with the German Packaging Act by taking immediate, structured action. These regulations create a clear framework that requires your attention now.

Before placing any packaged goods on the German market, you must register with the LUCID packaging register, managed by the Central Agency Packaging Register (ZSVR). This registration is free but mandatory, providing you with a unique Extended Producer Responsibility (EPR) number. Online marketplaces like Amazon are now required to verify this EPR number and will block sellers who cannot provide it. The registration process requires specific company details and a listing of all brand names under which you sell products.

To complete your registration, follow these essential steps:

1. Visit the official ZSVR LUCID portal to create your company’s account.
2. Enter all required master data, including company name, address, and VAT number.
3. List all brand names associated with the packaging you will place on the market.
4. Receive your unique LUCID (EPR) number upon completion.
5. Provide this number to your chosen dual system partner to link your accounts.
6. Report your licensed packaging volumes in both your LUCID account and to your dual system.

Many businesses overlook that this registration must be completed before a single item is sold. You can get help with LUCID registration to ensure every step is handled correctly. This foundational step is the gateway to full compliance.

After registering in LUCID, you must license your packaging volumes with a state-approved “dual system.” These private organizations manage the collection, sorting, and recycling of packaging waste on behalf of producers. Participation is funded by license fees, which are calculated based on the material type and weight of your packaging. This fee covers the cost of recycling the packaging you put into circulation across Germany. There are 11 accredited dual systems to choose from. Choosing the right partner ensures your financial contributions directly support a functioning circular economy.

Partnering with a dual system offers several key advantages:

• Fulfills your legal take-back and recycling obligations under VerpackG.
• Provides the necessary proof of system participation required by marketplaces.
• Ensures your packaging waste is collected from consumers and properly recycled.
• Gives you access to expert guidance on material classification and reporting.
• Helps you understand the dual system and its role in national recycling efforts.

This partnership is not just a legal formality; it is your direct contribution to Germany’s national recycling infrastructure.

Ongoing compliance requires accurate and timely data reporting to both the LUCID register and your dual system partner. Companies must submit an initial forecast of packaging volumes for the upcoming year. By May 15th of the following year, you must file a year-end report detailing the actual quantities of materials you placed on the German market. These reports must be identical across both platforms, as the ZSVR actively cross-references the data to identify discrepancies. Failure to report data correctly can lead to fines of up to €10,000. Accurate, harmonized reporting is the only way to prove continuous compliance. A streamlined process to fulfill your reporting duties is critical. With these reports, you are prepared for the next wave of regulations.

The new EU-wide Packaging and Packaging Waste Regulation (PPWR) entered into force on February 11, 2025, and will be fully applicable by August 12, 2026. This regulation harmonizes rules across all 27 member states, replacing previous directives with a single, binding framework. Key measures include mandatory packaging minimization, with a rule that empty space in transport packaging cannot exceed 50% starting in 2030. By 2030, all packaging must be designed for recycling, and minimum recycled content targets for plastic packaging will be enforced. These EU-level changes reinforce the urgency for businesses to adapt their packaging strategies now. The PPWR signals a major shift, making proactive compliance more important than ever. If you have not yet taken action, you must contact Deutsche Recycling immediately to ensure you are prepared for these new EU directives and can get your business compliant.

The consequences of non-compliance with the VerpackG are severe and immediate. Authorities can levy fines up to €200,000 per violation for failing to license your packaging with a dual system. Simple registration failures in the LUCID portal can incur penalties of up to €100,000. Beyond fines, you face an immediate ban on all sales in Germany and potential legal challenges from competitors, a common practice in the German market. Marketplaces like Amazon and eBay are legally obligated to de-list any seller who cannot prove their compliance. The risk of losing access to the entire German market is a reality for non-compliant businesses. The only way to secure your business is to get help with registration and licensing. Taking decisive action today is the only way to protect your business from these outcomes.

Navigating the complexities of the VerpackG and the upcoming PPWR demands expert knowledge and precise execution. Deutsche Recycling offers a comprehensive, full-service solution designed to ensure your business achieves and maintains 100% legal conformity. We handle LUCID registration, dual system licensing, and all data reporting requirements, freeing you to focus on your core operations. Our team of experts provides the clarity and support needed to manage your environmental obligations efficiently. Don’t wait for a penalty notice to take action. Contact Deutsche Recycling today for an individual consultation and secure your access to the German market. This partnership is your path to confident compliance.