The German Packaging Act, or VerpackG, applies to any company that is the first to place packaging filled with goods on the German market, which typically ends up with the private end consumer. For over 99% of US exporters or online sellers, this means you are considered the ‘producer’. The law establishes a ‘producer pays’ principle, making you financially responsible for the collection and recycling of your packaging materials inside Germany. This includes every component, from the cardboard box to the tape and bubble wrap. There are no minimum thresholds; the law applies from the very first package you ship. Since July 1, 2022, marketplaces like Amazon and eBay are legally obligated to verify your compliance, making adherence a prerequisite for market access. Understanding these core duties is the first step toward securing your business operations in Germany. You can find more details in our guide for international sellers. The next step involves official registration, a non-negotiable requirement.

Compliance with the VerpackG involves three mandatory actions that must be completed before your goods enter Germany. Failure in any one of these areas can halt your sales. The entire process is overseen by the Central Agency Packaging Register (ZSVR), a federal authority established in 2019. They maintain a public register called LUCID, which provides transparency and ensures a level playing field. The system was designed to stop ‘free-riders’, who previously cost compliant companies over €200 million annually. Follow these three steps to ensure you meet all legal requirements.

Here is the required 3-step process:

• LUCID Registration: You must register your company details in the LUCID packaging register. This is a public process and generates your unique EPR number, which is required by marketplaces.
• System Participation: You must sign a contract with a state-approved ‘dual system’ provider in Germany. This involves paying an annual license fee based on the volume and type of packaging materials you will place on the market.
• Data Reporting: You are required to report your packaging volumes to both your chosen dual system and the LUCID register. This ensures the data matches and confirms your financial contributions.

Once registered, you must select a partner to handle the financial aspects of recycling. Learn how to choose a dual system that fits your business needs. This decision directly impacts your annual compliance costs.

The consequences of ignoring the German Packaging Act are severe and immediate. Any breach of your obligations is considered an administrative offense and automatically leads to a ban on the distribution of your products in Germany. This means online marketplaces will delist your products, and customs may refuse entry of your shipments. Fines can be as high as €200,000 for failing to license your packaging with a dual system. Even simple administrative errors have high costs. Failure to register in the LUCID database can result in a fine of up to €100,000, while incorrect data reporting can incur a penalty of up to €10,000 for each instance. These are not idle threats; German authorities and your competitors actively monitor the public LUCID register for non-compliant companies. You can review the full legal requirements for shipping to understand the risks. The financial and reputational damage from these penalties far outweighs the cost of compliance, making proactive measures essential.

The law requires a license for all ‘sales packaging,’ which is any packaging that typically accumulates as waste at the end consumer’s location. This definition is broad and covers nearly everything a US e-commerce business would use. It is crucial to account for every single component to ensure your volume reports are accurate. An error in calculation can lead to penalties for incorrect data reporting. Many US sellers forget to include tertiary materials like tape or labels, which can lead to compliance gaps.

Your licensing obligations cover these common packaging types:

• Product packaging (the item’s own box or wrapper)
• Shipping boxes used for transport to the customer
• Void fill and cushioning materials (e.g., bubble wrap, air pillows, packing paper)
• Packaging tape and sealing materials
• Shipping labels and document sleeves
• Any plastic bags or films used to protect items

A detailed checklist for VerpackG compliance can help you prepare the necessary information for your registration and data reports. Properly classifying and quantifying your materials is a foundational part of the process.

The requirements of the German Packaging Act are not retroactive; they apply the moment you decide to enter the market. Procrastination creates direct business risk, as you cannot legally ship to Germany without a valid LUCID registration number. The registration and licensing process can take several days, and any delay means lost sales and potential customer service issues. It is critical for US companies to treat this as an immediate priority. The law is a key part of Germany’s plan to meet EU recycling targets, which are set to become even stricter under the new Packaging and Packaging Waste Regulation (PPWR). Acting now ensures you are not only compliant with current German law but also better prepared for future EU-wide regulations. If you have not yet taken action, you are already at risk of being blocked from the market. The solution is straightforward and ensures you can manage your German EPR obligations effectively. The final step is to secure a reliable partner to navigate the process for you.

Navigating foreign regulations can be complex, but you do not have to do it alone. Deutsche Recycling offers a complete service designed for international companies, providing a clear and efficient path to full compliance with the German Packaging Act. We handle the entire process on your behalf, from LUCID registration to dual system licensing and data reporting. Our service guarantees 100% legal conformity, allowing you to focus on your core business without worrying about German bureaucracy. For non-German-speaking businesses, our expert support removes language barriers and simplifies every step. Within just a few business days, we can have you fully registered and licensed. Don’t let regulatory hurdles block your access to one of Europe’s largest markets. Contact Deutsche Recycling today to ensure your business complies with all regulations quickly and correctly. Our team is ready to provide a no-obligation consultation and a tailored quote to meet your specific needs, ensuring you get help with registration immediately.