The German Packaging Act (VerpackG) applies to any company placing goods in packaging on the German market for the first time. This law makes you, the exporter, directly responsible for the entire lifecycle of your packaging materials. Since January 1, 2019, these rules have been mandatory for all business-to-consumer (B2C) sales. The regulations cover every component, including product boxes, shipping cartons, tape, and even cushioning materials. Ignoring this responsibility is no longer an option, as marketplaces now verify compliance. You must manage your German EPR obligations to maintain market access. Understanding these rules is the first of 3 critical steps to securing your business in Germany.

To legally sell in Germany, you must complete three non-negotiable actions. First, register with the LUCID Packaging Register, a step you must complete yourself. Second, you must sign a contract with a state-approved ‘dual system’ to pay licensing fees for your packaging volumes. Third, you must regularly report these volumes to both LUCID and your chosen system. These steps are not optional and apply from the very first package you ship. Here is a breakdown of the core requirements:

• Register your company with the ZSVR’s LUCID portal before any goods are shipped.
• Provide all requested company data, including brand names and tax numbers.
• Select a dual system partner to handle the nationwide collection and recycling of your materials.
• Calculate and declare your anticipated annual packaging volumes by material type (e.g., paper, plastic, glass).
• Pay the corresponding licensing fees to your dual system partner.
• Submit identical volume reports to both your dual system and the LUCID register.

Completing these actions is essential to ensure Verpackungsgesetz compliance and avoid immediate penalties.

Your first mandatory task is registering in the LUCID portal, managed by the Central Agency Packaging Register (ZSVR). This registration is free of charge but must be handled directly by your company, not a third party. During the process, you will receive your unique EPR number, which is required for all subsequent steps. Since July 1, 2022, online marketplaces like Amazon and eBay are obligated to collect and verify this number from their sellers. Without a valid LUCID number, you face an immediate sales ban on these platforms. This registration is the foundation of your compliance journey, so it is vital to understand the process for sellers.

After registering with LUCID, you must license your packaging quantities with a dual system. This is how you contribute financially to Germany’s nationwide recycling infrastructure, a core principle of the Extended Producer Responsibility (EPR) framework. You will pay fees based on the weight and type of materials you place on the market, such as cardboard, plastic, and glass. There are several approved dual system providers, and choosing the right one is a key decision. Failure to license your packaging is a separate offense from failing to register and carries its own heavy fines. It is critical to join a German packaging scheme to fulfill this obligation. This partnership ensures your packaging is properly collected and processed, but you still have reporting duties to complete.

Your final ongoing duty is to report your packaging data accurately. You must submit reports on your packaging volumes to both your dual system partner and the LUCID register. These two reports must be identical and submitted according to the required schedule, typically annually. Any discrepancies between the two data sets can trigger an audit by the ZSVR. For companies exceeding certain volume thresholds (e.g., 80,000 kg of glass), a formal Declaration of Completeness, verified by a registered auditor, is also required. Incorrect or late reporting is an administrative offense that can lead to fines up to €10,000. Properly managing these reports is key to fulfill your reporting duties and maintain your compliant status.

Ignoring the VerpackG has severe financial and operational consequences. Authorities can impose fines of up to €200,000 for violations such as failing to register or not participating in a dual system. Beyond fines, you face an immediate and legally enforceable distribution ban on all your products in Germany. Competitors can also issue costly legal warnings for unfair competition, adding further financial strain. Since 2022, fulfillment providers are also prohibited from handling goods for non-compliant companies. The risk is not just a potential fine; it’s a complete shutdown of your German sales channels. To avoid this, you must understand the legal requirements fully.

The requirements of the German Packaging Act are complex and the deadlines are absolute. The EU’s directives are clear: producers and exporters must take responsibility for their packaging waste now. Navigating the registration, system participation, and reporting requirements demands expertise and precision. Any misstep can halt your business operations in Germany, which has a consumer market of over 83 million people. We guarantee 100% legal conformity for your company. Deutsche Recycling offers a complete service to manage these obligations on your behalf, ensuring you can focus on your core business without risking penalties. Contact us immediately to ensure you can continue to fulfill German packaging recycling obligations for exporters without interruption.