The German Packaging Act, or VerpackG, is a 2019 law that implements the European Packaging Directive 94/62/EC into German national law. Its primary goal is to reduce the environmental impact of packaging waste by making producers responsible for the entire life cycle of their packaging. In 2022, Germany generated 19 million tonnes of packaging waste, making these regulations critical. The law affects any company that is the first to place packaged goods on the German market, including manufacturers, importers, and online retailers shipping cross-border.

This principle is called Extended Producer Responsibility (EPR), and it applies to all packaging materials, including cardboard, plastic, glass, and metals. If your packaging ultimately ends up with a private consumer in Germany, you are considered the ‘initial distributor’ and must comply. The law applies from the very first package you ship, with no minimum quantity. These rules form a complex but mandatory system for market access.

To comply with the German Packaging Act, you must fulfill three key duties without fail. These obligations are monitored by the Central Agency Packaging Register (Zentrale Stelle Verpackungsregister – ZSVR) and are non-negotiable for market participation. Overlooking any of these steps can lead to immediate penalties. The entire process ensures you contribute to the costs of recycling the packaging you introduce.

Here are your primary responsibilities:

• 1. Register with the LUCID Packaging Register: Before placing any goods on the market, you must register your company and brand names with the ZSVR’s public LUCID register.
• 2. Participate in a Dual System: You must sign a contract with a licensed ‘dual system’ to manage the collection and recycling of your packaging materials across Germany.
• 3. Report Your Packaging Data: You are required to regularly report the volume and material types of your packaging to both your chosen dual system and the LUCID register.

Fulfilling these three duties is the foundation of your legal operation in Germany under the packaging regulation. The next step is understanding the specifics of each requirement.

Your first mandatory action is to register with the LUCID packaging register, which is managed by the ZSVR. This registration is free and must be completed by the company itself; it cannot be delegated to a third party. Upon successful registration, you will receive your unique EPR number, which serves as proof of compliance for marketplaces and partners. Since July 2022, online marketplaces are required to verify this number before allowing you to sell.

Failure to register can result in a fine of up to €100,000 per violation. The register is public, allowing competitors and authorities to check your compliance status at any time. This transparency is designed to ensure a fair market where all producers share the financial burden of recycling. This registration is a critical component of your extended producer responsibility in Germany.

After registering in LUCID, you must license your packaging volumes with a dual system. These privately organized systems are responsible for the physical collection, sorting, and recycling of packaging waste from consumers throughout Germany. By paying a license fee to a dual system, you are financing this nationwide infrastructure. The fee is based on the weight and material type of the packaging you place on the market.

You must complete this step before your products go on sale. The process involves these actions:

1. Select one of the approved dual systems.
2. Sign a system participation contract.
3. Provide an estimate of your annual packaging volumes.
4. Pay the corresponding license fee.
5. Report the name of your dual system in your LUCID account.

This system ensures that the nearly 155.4 kg of packaging waste recycled per capita in Germany is properly managed. Without this participation, your products cannot be legally sold.

Ignoring the German Packaging Act carries substantial financial and operational risks. Authorities can impose fines of up to €200,000 for failing to participate in a dual system. Simple registration errors can cost up to €100,000, and failure to report data can lead to penalties of €10,000. These fines can be applied for each individual case of non-compliance.

Beyond fines, authorities can issue an immediate sales ban, effectively halting your business in Germany. Competitors can also issue legal warnings and take civil action against non-compliant companies, creating additional legal costs and business disruptions. The increasing number of warning letters regarding the German Packaging Act shows that enforcement is active. It is imperative that you act now to avoid these outcomes. If you are unsure of your status, contact Deutsche Recycling for immediate assistance.

The regulatory landscape for packaging is continuously evolving, making immediate action even more critical. Since January 1, 2022, there has been a mandatory deposit on almost all single-use plastic beverage bottles and cans. Furthermore, new targets are already set for the near future. As of January 1, 2025, single-use PET beverage bottles must contain at least 25% recycled plastic. This threshold will increase to 30% for all single-use plastic bottles by 2030.

These changes underscore the EU’s commitment to a circular economy and require constant vigilance from businesses. Waiting to adapt can leave your company non-compliant overnight. The requirements of the Packaging and Packaging Waste Regulation are not static. Proactive compliance is the only way to ensure uninterrupted market access. Now is the time to review your obligations and secure your compliance. For those who have not yet taken steps, Deutsche Recycling offers expert guidance to navigate these regulations swiftly.

The complexity of the German Packaging Act demands expert handling to ensure 100% legal conformity. Deutsche Recycling offers a full-service solution to manage all your EPR obligations. We handle LUCID registration, dual system contracts, and all data reporting on your behalf. Our service is designed to relieve your administrative burden, allowing you to focus on your core business with complete peace of mind.

By partnering with us, you gain more than just compliance; you gain a shield against legal risks and financial penalties. We ensure every requirement is met correctly and on time. Do not let regulatory hurdles disrupt your business. Take action now to secure your operations in Germany. Contact us today for a personalized consultation and let our experts handle your compliance with the German Packaging Act.