The German Packaging Act (VerpackG) affects any business that is the first to place goods in packaging on the German market, which typically ends up with the private consumer. This includes manufacturers, importers, and online sellers, with no minimum threshold for the amount of packaging. The law, which replaced the 1991 Packaging Ordinance, aims to increase recycling rates significantly, with a target of recycling 63% of plastics by 2022. The legislation implements the EU’s Packaging and Packaging Waste Directive, making compliance a legal necessity for market access. Understanding your role as a ‘first distributor’ is the initial step in this mandatory process. You can find more details in our complete guide to German EPR laws. The first concrete action you must take is registering with the central authority.

Before your first packaged item enters Germany, you must register with the LUCID Packaging Register. This online platform is managed by the Central Agency Packaging Register (ZSVR), a federal authority established to oversee the system. Registration is free of charge but cannot be delegated to a third party; it must be completed by your company directly. Upon successful registration, you receive your unique EPR number, which is required for all subsequent steps. The ZSVR makes registration data public to ensure transparency, allowing anyone to check a company’s compliance status. The process requires specific company details, as outlined in this checklist for LUCID registration. After securing your EPR number, your next task is to engage with a recycling scheme.

With your EPR number, you must sign a contract with one of Germany’s ‘dual systems’. These are privately organized, state-approved companies responsible for the nationwide collection, sorting, and recycling of packaging waste from consumers. This step, known as system participation, is how you pay for the recycling of your packaging. The cost, or license fee, is calculated based on the material type and weight of the packaging you plan to sell in a calendar year. There are several dual systems to choose from, so it is important to select one that fits your needs. Failure to license your packaging with a dual system is a direct violation of the VerpackG and carries fines of up to €200,000. You can understand the German dual system in more detail on our services page. Once your contract is active, you must report your licensed volumes.

Compliance requires a two-part data reporting process. You must report the packaging volumes you have licensed with your dual system directly to the LUCID register. These two reports—to your dual system and to LUCID—must be identical and submitted without delay. This ensures the ZSVR can cross-reference the data and verify that all packaging in the market is accounted for. For companies exceeding certain thresholds, an additional step is required. Here are the thresholds for the annual Declaration of Completeness:

• More than 80,000 kg of glass
• More than 50,000 kg of paper, paperboard, or cardboard
• More than 30,000 kg of lightweight packaging (e.g., plastics, aluminum)

If you exceed any of these volumes in a calendar year, you must submit a Declaration of Completeness by May 15 of the following year. This declaration must be audited by a registered inspector. Learn more about how to report packaging volumes correctly. These reporting duties are the key to avoiding significant legal and financial trouble.

The consequences for failing to fulfill your packaging reporting duties in Germany are severe and immediate. Authorities can issue fines of up to €200,000 for not participating in a dual system. Incorrect or missing LUCID registration can result in penalties of up to €100,000 per violation. Beyond fines, non-compliant companies face an immediate ban on sales, meaning your products can be legally barred from the German market. Since July 1, 2022, online marketplaces and fulfillment providers are legally required to verify the compliance of their sellers. If you cannot provide a valid EPR number, platforms like Amazon will block your listings, and logistics partners cannot ship your goods. These measures show why you must fulfill German packaging recycling obligations without delay. The complexity of these rules makes expert guidance essential.

Navigating the VerpackG, LUCID, and dual system requirements involves multiple steps, strict deadlines, and zero tolerance for errors. The law demands that every company selling to German consumers take responsibility for their packaging waste. The risk of six-figure fines and a complete loss of market access is too high to ignore. You must act now to ensure your operations are fully compliant with all EU directives and German laws. For over 25 years, Deutsche Recycling has provided expert, service-oriented support to companies navigating these regulations. We guarantee 100% legal conformity for your business. Don’t leave your market access to chance. Contact the experts at Deutsche Recycling today for a consultation to secure your compliance as quickly as possible.