The European Union has intensified its environmental standards with the new Packaging and Packaging Waste Regulation (PPWR). This regulation mandates that all packaging on the EU market must be recyclable in an economically viable way by 2030. It introduces binding waste reduction targets for member states, starting with a 5% per capita reduction by 2030 compared to 2018 levels. These new rules replace the previous directive and apply directly to economic operators, demanding immediate attention. Ignoring these updated EU directives is no longer an option for any business. The transition period is over, and enforcement is active. You must comply with the Packaging Act to continue operating. This new legal landscape requires a proactive strategy to ensure your business remains compliant across all 27 member states.

To correctly declare packaging materials, you must first understand their classification under the German Packaging Act (VerpackG). The law distinguishes between several types, each with specific obligations. Misclassification is a common error leading to incorrect declarations and potential fines. Your primary responsibility lies with packaging that typically ends up with private consumers. This includes not just the product’s box, but also all shipping materials. Here is a breakdown of the main categories:

• Sales Packaging: Materials the end-consumer purchases as a single unit (e.g., a tube of toothpaste).
• Secondary Packaging: Grouped packaging or outer layers that are removed before use (e.g., the box holding multiple snack bars).
• Shipment Packaging: Materials used for e-commerce, including boxes, tape, and filling materials, sent to the end consumer.
• Transport Packaging: Business-to-business (B2B) packaging used to protect goods during transit that does not reach the end consumer.

Properly identifying each packaging type is the first step toward 100% compliance. Understanding what is required for compliance is foundational. This classification directly impacts the volume data you will report.

Compliance with the VerpackG is a multi-step process that requires careful execution. The LUCID Packaging Register is the central tool for transparency and enforcement, managed by the ZSVR. Following these four steps is mandatory for every company selling to German consumers. Missing any one of these steps can result in a distribution ban. Here is the required process:

1. Register with the LUCID Database: Create an account on the LUCID portal, providing your company details and the brand names you sell under. You will receive your unique EPR number upon completion.
2. License with a Dual System: Contract with a state-approved recycling scheme (a ‘dual system’). You will pay a fee to this system based on your projected packaging volumes for the year.
3. Declare Your Volumes: Report your licensed packaging volumes and material types to both your chosen dual system and the LUCID register. The data reported in both systems must match exactly.
4. Add Your LUCID Number: Provide your LUCID EPR number to any online marketplaces (like eBay or Amazon) or fulfillment service providers you use, as they are now required to verify it.

This checklist for LUCID registration ensures no critical step is missed. The process connects your company directly to the recycling system.

Accurate data is the core of your compliance duty. You must report the total mass for each type of packaging material you place on the German market. This includes paper, plastic, glass, aluminum, and other materials. Companies must submit an initial forecast of packaging volumes for the upcoming year. They must also provide a year-end report of the actual volumes placed on the market. For businesses exceeding certain thresholds, such as 50,000 kg of paper or 30,000 kg of plastics annually, a formal Declaration of Completeness is required. This declaration must be audited by a registered third-party verifier before its submission by May 15th of the following year. The dual reporting obligation is a frequent point of failure; every report to your dual system must be mirrored in LUCID without delay. Learning how to report packaging volumes correctly is essential. This detailed reporting ensures you pay your fair share for recycling.

The dual systems are the operational backbone of Germany’s recycling infrastructure. While the LUCID register is for transparency and monitoring, a dual system physically organizes the collection and recycling of packaging waste from consumers. Participation is mandatory for all B2C packaging. By paying a license fee to a dual system, you finance the nationwide collection and processing of materials like paper, plastic, and glass. There are over 10 approved dual systems to choose from. Your LUCID registration is invalid without a corresponding, active license with a dual system. This two-part structure ensures that producer responsibility extends from declaration to the actual recycling process. You can understand the German dual system as the practical fulfillment of your legal obligations. This system is what turns your declaration into environmental action.

Non-compliance with 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. For companies that register but fail to participate in a dual system, the penalty can be as high as €200,000 for each violation. Even simple data reporting errors can lead to fines of up to €10,000. Beyond financial penalties, authorities can issue a distribution ban, immediately stopping you from selling your products in Germany. Competitors can also report non-compliant companies, creating additional legal pressure. It is vital to register your shipping materials properly to avoid these outcomes. These strict enforcement measures underscore the importance of getting your declaration right from the start.

The legal requirements for packaging are no longer a future concern; they are a present-day reality. The EU and German authorities have created a system where non-compliance is easily detectable and penalties are significant. Every business, from small online sellers to large manufacturers, must take action. The complexity of material classification, volume calculation, and dual reporting demands expert oversight. If you have not yet taken steps to comply, your business is at immediate risk. We urge you to act now to protect your market access and avoid financial penalties. For a seamless and guaranteed path to 100% compliance, contact the experts at Deutsche Recycling today. We handle the entire process, allowing you to focus on your core business. Explore our blog for more on registration and labeling obligations.