The German Packaging Act (VerpackG) implements the EU’s Packaging and Packaging Waste Directive 94/62/EC, establishing Extended Producer Responsibility (EPR). This framework makes you, the producer, financially responsible for the collection and recycling of every piece of printed material you place on the German market. The law applies from the very first item, with no minimum volume threshold. Since a 2022 amendment, online marketplaces are also required to verify your compliance, making it impossible to ignore. Many businesses mistakenly believe these rules only apply to traditional boxes, but they cover a vast range of paper products. You can get a complete analysis of your EPR obligations to be certain. These regulations are designed to increase recycling rates, with Germany targeting a 75% recycling rate for paper and cardboard. This legal shift requires a proactive approach to compliance.

The term ‘producer’ under VerpackG is broad and applies to the entity that first introduces the printed material into German commerce. This includes more than just traditional publishers. Over 50% of obligated producers may be international e-commerce businesses. You are considered a producer if you are one of the following:

• A German-based publisher or printer distributing within Germany.
• An importer bringing printed goods into the country for sale.
• An international online retailer shipping printed matter directly to German end-consumers.
• A company using large volumes of catalogues, flyers, or direct mail for advertising.

Even if you use a fulfillment service, the obligation to comply likely remains with you as the one commissioning the service. It is essential to clarify responsibility in your contracts, but the default responsible party is the one whose name is on the product. Understanding your role is the first step toward fulfilling producer responsibility. This clarity is vital before you can take the necessary registration steps.

To comply with your EPR obligations for printed matter, you must complete three mandatory steps before selling in Germany. The process involves interaction with two separate entities and requires precise data management. Overlooking just one step results in total non-compliance. Here is the required process:

1. Register with LUCID: You must register your company in the public LUCID register, which is managed by the Central Agency Packaging Register (ZSVR). This provides you with your unique EPR number.
2. Sign with a Dual System: You must contract with a state-approved recycling scheme, known as a ‘dual system’. This is a separate, private company that handles the physical collection and recycling of your materials for a license fee.
3. Declare Your Volumes: You are required to report the exact mass and material type of your printed products to both the LUCID register and your chosen dual system. These reports must be identical and are subject to audits.

These actions must be completed before you place any goods on the market. This is not a retroactive process. Acting now is critical, and our experts can help you navigate German EPR laws efficiently. Once registered, you must maintain your reporting schedule to remain compliant.

Ignoring your EPR obligations for printed matter is a significant financial and operational risk. German authorities can impose fines of up to €200,000 for non-compliance with registration or system participation duties. Beyond fines, authorities can issue an immediate sales ban, effectively stopping your business in Germany. Since July 1, 2022, online marketplaces like Amazon and eBay are legally mandated to suspend non-compliant listings. A single report of non-compliance from a competitor can trigger an investigation and lead to these severe penalties. The public nature of the LUCID register makes it simple for anyone to check your status. The potential revenue loss from a sales ban often exceeds the cost of the fines. You can learn more about the German dual system to start the process. The risks demonstrate why immediate action is the only sound business decision.

The requirements of the German Packaging Act are complex, and the consequences of failure are severe. The EU is only tightening these regulations with the new Packaging and Packaging Waste Regulation (PPWR), which will introduce even stricter rules by 2030. Waiting to act is not a viable strategy. You must ensure your company is registered, licensed, and reporting correctly to continue operating in the German market. The entire process can be managed for you, ensuring 100% legal conformity without diverting your focus from your core business. For companies that have not yet taken action, the situation is urgent. To comply with all regulations as quickly as possible and secure your business, you should seek expert guidance immediately. Contact Deutsche Recycling today for an individual consultation and let our experts handle your EPR compliance from start to finish.