The Verpackungsgesetz (VerpackG) establishes Extended Producer Responsibility (EPR) for all companies selling to German consumers. This law, updated in July 2022, makes you financially responsible for the recycling of every piece of packaging you introduce. Your obligations apply from the very first item you ship, with zero minimum quantity exemptions.

Compliance involves three non-negotiable duties. First, you must register with the LUCID Packaging Register, a public database managed by the Central Agency Packaging Register (ZSVR). Second, you must license your packaging volumes by signing a participation agreement with a state-approved dual system. Third, you must regularly report your packaging data to both LUCID and your dual system partner. You can comply with the German Packaging Act by following these steps precisely.

Failure to complete any of these 3 steps means you are not compliant and can face immediate penalties. These regulations apply to all B2C sales and even some B2B transactions where waste is disposed of similarly to households. The law now requires online marketplaces like Amazon and eBay to verify your compliance, making these obligations unavoidable for continued sales. Understanding these duties is the first step toward securing your business operations in Germany.

Before placing any packaged goods on the market, you must complete your registration in the LUCID portal. This registration is free of charge but cannot be delegated to a third party; you must complete it yourself. The ZSVR makes your company name, address, and brand names publicly visible in the register to ensure 100% transparency.

The process requires specific company information. You will need to provide the following details to create your account:

• Company name and address
• VAT identification number (or tax number)
• A list of all brand names placed on the market
• Contact details, including an email address

After submitting your details, you will receive a verification link that must be confirmed within 24 hours. Upon confirmation, you are issued a unique EPR registration number, which serves as proof of your initial registration. This number is essential for the next steps, including signing with a dual system and providing proof to online marketplaces. A checklist for LUCID registration can simplify this process. Remember, without a valid LUCID registration number, your products are subject to an immediate distribution ban. This registration is the foundational step for all further compliance activities.

After registering in LUCID, you must license your packaging with a dual system. This fulfills your system participation obligation, a core requirement of the Verpackungsgesetz for all sales, shipping, and product packaging. These systems organize the nationwide collection, sorting, and recycling of packaging waste on behalf of producers. There are around 10 accredited dual systems to choose from in Germany.

The process involves paying a license fee based on the materials and weight of your packaging. You must provide an accurate forecast of the packaging volumes you will place on the German market for the calendar year. These volumes are reported by material type, such as paper, plastic, glass, and aluminum. The fees you pay directly fund Germany’s recycling infrastructure. You can learn more about the German dual system and how it operates. You must provide your LUCID EPR number to your chosen dual system to link your registration to your license. This connection is critical for valid compliance. Without it, your registration is incomplete.

Your obligations do not end after registration and licensing. Ongoing data reporting is a mandatory part of VerpackG compliance. You must report the exact packaging volumes you placed on the market to both the LUCID register and your dual system partner. The data reported to both must match perfectly, as the ZSVR cross-references these reports to detect discrepancies.

Reporting frequency depends on your agreements, but at least one annual report is standard. Businesses with high packaging volumes have an additional requirement. If you exceed 80,000 kg of glass, 50,000 kg of paper, or 30,000 kg of other materials, you must submit an audited Declaration of Completeness by May 15th of the following year. Even a 1 kg difference between reports can trigger an investigation and potential penalties. Accurate and timely reporting is essential to fulfill your reporting duties and maintain your legal status. This ongoing diligence ensures your business remains compliant long-term.

Non-compliance with the Verpackungsgesetz carries severe consequences that can halt your German operations entirely. Authorities can issue fines of up to €200,000 for failing to participate in a dual system. Fines for improper or missing LUCID registration can reach €100,000 per case. Beyond fines, authorities will impose an immediate distribution ban on all non-compliant packaged goods.

Competitors can also issue civil warnings, leading to costly legal battles and further damages. Since July 2022, online marketplaces and fulfillment providers are legally obligated to verify your compliance. If you cannot provide a valid EPR number, they must block your sales, effectively cutting off your access to the German market. The financial and operational risks are too high to ignore. You must avoid EPR fines by ensuring every step is complete. The only way to operate legally is to ensure full compliance before you ship.

Navigating the complexities of the Verpackungsgesetz requires constant attention to detail and regulatory changes. For many businesses, managing these obligations internally creates a significant administrative burden. It distracts your team from focusing on core business activities like sales and product development. An error in registration, licensing, or reporting can jeopardize your entire German market presence.

Deutsche Recycling offers a comprehensive, full-service solution to manage your environmental compliance. We handle the entire process on your behalf, from initial registration and system participation to ongoing data management and reporting. Our experts ensure you are 100% compliant with all current and future regulations under the German Packaging Act. We provide the legal certainty you need to operate confidently and without risk. If you have not yet taken action, the time is now. Contact Deutsche Recycling to secure your compliance as quickly as possible and protect your business from penalties.