The German Packaging Act (VerpackG) went into effect on January 1, 2019, replacing the previous Packaging Ordinance. This law applies to all companies, regardless of size, that are the first to place packaged goods on the German market. This includes manufacturers, importers, online retailers, and distributors shipping products cross-border. The primary goal is to reduce packaging waste and increase recycling rates, holding producers accountable for the entire lifecycle of their packaging. Since July 1, 2022, these rules have expanded, making compliance checks by marketplaces and fulfillment providers mandatory. Any business shipping even one package to a German end-consumer falls under this law. You can comply with the German Packaging Act by following a clear set of rules. This legislation is Germany’s national implementation of the EU’s directive on packaging waste, setting a high bar for environmental responsibility.

To comply with the VerpackG, every business must fulfill three key duties without exception. Overlooking just one of these steps can lead to significant operational and financial penalties. These obligations form the foundation of Germany’s Extended Producer Responsibility (EPR) framework for packaging. Here are the required actions:

• 1. LUCID Registration: You must register your company with the Central Agency Packaging Register (ZSVR) in the LUCID portal before any packaged goods enter Germany.
• 2. System Participation: You are required to license your packaging volumes with a dual system, which organizes the collection and recycling of your materials nationwide.
• 3. Data Reporting: You must report the volume and material types of your packaging to both your chosen dual system and the LUCID portal.

Fulfilling these three duties is mandatory to legally operate in the German market. You can get your German EPR number quickly to begin the process. These steps ensure your business contributes financially to the recycling infrastructure your packaging relies upon.

The first step toward compliance is registering in the LUCID portal, which is managed by the ZSVR. This registration is free of charge but must be completed by the company itself; it cannot be delegated to a third party. Upon successful registration, you receive your unique EPR number, which serves as proof of compliance for marketplaces like Amazon and fulfillment providers. Since July 2022, these platforms are legally required to verify your registration and can block your sales for non-compliance. You must have this registration number before your first product is shipped. The process requires your company details, VAT number, and brand names associated with the packaging. For businesses outside Germany, LUCID registration for non-German speakers can be managed with expert support. This registration creates transparency and ensures all market participants are accounted for.

Ignoring the German Packaging Act carries severe financial and operational risks. Authorities can impose fines of up to €100,000 for failing to register with LUCID correctly. The penalty for not participating in a dual system is even higher, reaching up to €200,000 per violation. Beyond fines, authorities can issue an immediate ban on the distribution of your products in Germany, effectively shutting down your access to the market. Competitors can also take legal action against non-compliant companies, creating additional pressure. Since 2022, online marketplaces are obligated to delist sellers who cannot provide a valid EPR number. It is critical to avoid common errors in registration to prevent these outcomes. These strict enforcement measures demonstrate Germany’s commitment to the law’s objectives.

After registering with LUCID, you must license your packaging with a state-approved recycling program, known as a dual system. This is how you pay for the collection and recycling of the packaging you put into circulation. You pay a license fee based on the weight and type of materials you use, such as paper, plastic, and glass. There are several approved dual systems to choose from, and you must report your licensed volumes to both the system and LUCID. This system participation is what fulfills your financial responsibility under the law. The fees you pay directly fund the household recycling infrastructure across Germany. You must join a German packaging scheme to legally sell in the country. This step is essential for completing your compliance journey.

The German Packaging Act is not an isolated piece of legislation; it is the national implementation of the EU Packaging and Packaging Waste Directive 94/62/EC. This directive establishes a framework for all member states to prevent packaging waste and promote reuse and recycling. The EU is moving towards even stricter regulations with the upcoming Packaging and Packaging Waste Regulation (PPWR), which will further harmonize rules and increase recycling targets across Europe. This means that taking action now is not just about Germany—it is about aligning your business with the future of European environmental compliance. Waiting to act exposes your business to immediate legal risks and potential exclusion from the entire EU market. To comply with these regulations quickly, you should contact Deutsche Recycling for assistance. We ensure your business meets all current and future requirements without delay.