The German Packaging Act (VerpackG) applies to any company that is the first to place packaged goods on the German market. This includes manufacturers, importers, online retailers, and distributors, with no minimum quantity thresholds. Even shipping a single item to a German consumer makes you a ‘producer’ under the law. The act covers all packaging materials that end up with the end consumer, including product boxes, filling materials, and shipping cartons. Since July 2022, registration is mandatory for all types of packaging, including B2B transport packaging. Failing to comply can lead to fines of up to €200,000 per violation. Understanding your specific duties is the first step toward securing your business. You must take action now to comply with these EU directives. This legal framework requires a proactive approach to avoid severe penalties.

Before placing any goods on the market, your first mandatory step is to register with the LUCID packaging register. This online platform is managed by the Central Agency Packaging Register (ZSVR), a government authority created to ensure transparency. The registration process is free of charge but must be completed by the company itself; it cannot be delegated to a third party. During registration, you will provide your company details and list the brand names under which you sell products. Upon completion, you receive a unique EPR number, which is required for all subsequent steps and must be provided to online marketplaces like Amazon or eBay. Without a valid LUCID number, you are legally barred from selling in Germany. This registration is the foundation of your compliance, so completing it accurately is essential before you choose a German dual system.

After registering in LUCID, you must sign a contract with a state-approved ‘dual system’. These privately organized companies manage the nationwide collection, sorting, and recycling of packaging waste on behalf of producers. By paying a license fee to a dual system, you are financing your share of the recycling costs for the packaging you circulate. The fee is calculated based on the type and weight of the materials you use, such as paper, plastic, and glass. There are around 10 different dual systems to choose from in Germany. Your choice of a dual system directly impacts your annual compliance costs. It is crucial to find a provider that aligns with your business volume and service needs. This partnership is a core requirement for Verpackungsgesetz compliance and must be established before you sell any products.

Joining a German packaging scheme involves a clear sequence of actions that every business must follow. This process ensures you meet all legal requirements under the VerpackG from day one.

1. Calculate Annual Packaging Volumes: Forecast the total weight of each packaging material (e.g., cardboard, plastic, glass) you expect to place on the German market in a calendar year. Accuracy is key, as this data forms the basis of your license fee.
2. Register with LUCID: Complete your company registration at the ZSVR’s LUCID portal to obtain your mandatory EPR number. This must be done before any other steps are taken.
3. Contract with a Dual System: Use your packaging volume calculations to get a quote and sign a participation agreement with a licensed dual system. You will pay them a fee to cover your recycling obligations.
4. Report Your Data: After signing the contract, you must report your licensed packaging volumes and the name of your dual system to the LUCID register. This step links your registration to your financial participation, completing the initial compliance loop.

Following these steps methodically is critical for anyone wondering how to join a German packaging scheme correctly.

Compliance with the VerpackG is an ongoing process that extends beyond the initial setup. You are required to submit regular data reports to both your dual system and the LUCID register. Typically, you provide an initial forecast of your packaging volumes for the upcoming year. At the end of the year, you must submit an end-of-year declaration detailing the actual quantities you placed on the market. If your volumes exceed certain thresholds (e.g., 80 tonnes of glass), you must also submit a Declaration of Completeness, which has to be audited by a registered expert. Inaccurate or late reporting can trigger fines of up to €10,000. Diligent record-keeping is essential to declare packaging materials correctly and avoid penalties.

The consequences of ignoring the German Packaging Act are severe and can halt your business operations in Germany entirely. Authorities can impose fines of up to €200,000 for failing to participate in a dual system and up to €100,000 for not registering with LUCID. Furthermore, non-compliant companies face an immediate distribution ban on their products. Since the LUCID register is public, competitors can easily identify and report unregistered businesses, leading to legal action. Online marketplaces are now legally obligated to verify that their sellers are compliant, and they will delist any seller who cannot provide a valid EPR number. The risk of inaction is not just financial; it’s a direct threat to your market access. To avoid these outcomes, you must get help with registration immediately.

Navigating the complexities of the VerpackG, from calculating volumes to managing ongoing reporting, creates a significant administrative burden. For international companies, this challenge is magnified. Partnering with a specialist like Deutsche Recycling removes this burden and provides 100% legal certainty. We handle every aspect of your packaging compliance.

• Management of your LUCID registration and data reporting.
• Selection of the most cost-effective dual system for your needs.
• Ongoing monitoring of legislative changes to ensure you remain compliant.
• A single point of contact for all your EPR obligations in Germany.

By entrusting us with your compliance, you free up resources to focus on your core business. Readers who have not yet taken action should contact Deutsche Recycling immediately to comply with the regulations as quickly as possible. Let our experts manage your obligations under the German Packaging Act.