Operating in Germany means complying with the German Packaging Act (VerpackG), which has been in effect since January 1, 2019. This law establishes Extended Producer Responsibility (EPR), making you accountable for your packaging’s entire lifecycle. Every company, including international online retailers, must register with the LUCID Packaging Register before selling any packaged goods. You must also join a dual system to manage the collection and recycling of your packaging waste.

The new EU Packaging and Packaging Waste Regulation (PPWR) adds another layer of requirements, which will be directly applicable from August 12, 2026. The PPWR mandates that by 2030, all packaging must be recyclable or reusable, setting ambitious new targets. This regulation is not an amendment but a complete overhaul, creating uniform rules across all 27 EU member states. Understanding how these two laws interact is the first step toward full compliance. You can learn more about how to comply with the German Packaging Act on our website.

These regulations create a challenging landscape for businesses, demanding immediate and informed action to ensure continued market access.

You cannot legally market packaging as ‘compostable’ in Germany without official certification. The key standard is EN 13432, which specifies the requirements for packaging recoverable through industrial composting and biodegradation. This European standard is the benchmark used by certification bodies like DIN CERTCO and TÜV SÜD to validate compostability claims. Certification is not a simple self-declaration; it involves a rigorous, multi-stage testing process.

The testing procedure for EN 13432 certification includes several critical steps:

• Biodegradation: At least 90% of the organic material must convert into CO2 within 6 months.
• Disintegration: After 12 weeks in an industrial composting environment, no more than 10% of the original mass can remain in fragments larger than 2 mm.
• Chemical Analysis: The material must meet strict limits for heavy metals and other toxic substances.
• Ecotoxicity Test: The resulting compost must not negatively affect plant growth or the environment.

Only packaging that passes all five tests can receive the certificate and be considered legally compostable. This process ensures that your materials do not harm Germany’s recycling and composting infrastructure. To learn more, explore how to ensure your packaging is compliant.

Licensing your compostable packaging in Germany involves more than just certification; it requires active participation in the country’s EPR system. The process ensures you contribute to the costs of managing packaging waste. Overlooking any step can lead to immediate sales prohibitions. The first step is to streamline your packaging licensing process.

Follow these essential steps to achieve compliance:

1. Certify Your Packaging: Engage a certified body like TÜV SÜD to test your materials against the EN 13432 standard. This provides the official proof of compostability required for the German market.
2. Register with LUCID: Before placing any products, register your company and packaging types with the Central Agency Packaging Register (ZSVR) via the LUCID portal. This is a mandatory first step for all producers.
3. Join a Dual System: Contract with a dual system provider in Germany. You will pay license fees based on the material type and weight of your packaging placed on the market.
4. Declare Your Data: Regularly report the volumes of your packaging materials to both your dual system and the LUCID register. Accurate data reporting is a legal obligation.

Failure to register with LUCID before selling goods is a direct violation and can trigger fines of up to €200,000. This structured process is critical for maintaining legal standing in the German market.

The German authorities enforce the VerpackG with zero tolerance for non-compliance. The risks are not just financial; they can halt your entire German operation. Fines for violations, such as failing to register or incorrect data reporting, can reach €200,000 per case. Additionally, competitors can issue legal warnings and take civil action against non-compliant companies, creating further legal and financial burdens.

Under the new PPWR, the stakes get even higher. From 2030, packaging that does not meet strict recyclability or reusability criteria will be banned from the EU market entirely. For compostable packaging, specific applications like tea bags and fruit stickers must be compostable by February 2028. The transition period is short, and companies that wait will face significant disruption. You must act now to get ready for circular economy laws.

The message from both German and EU regulators is clear: compliance is mandatory, and the time to prepare is now.

The regulatory landscape for compostable packaging is complex and constantly evolving. The deadlines set by the EU are fast approaching, and the requirements of the VerpackG are already in full force. Attempting to navigate these laws without expert guidance can lead to costly errors and market exclusion. It is imperative that you take action now to ensure your business is protected.

Deutsche Recycling offers a complete service to manage your environmental compliance obligations. We handle the entire process, from navigating the certification requirements under EN 13432 to managing your LUCID registration and dual system participation. Our experts ensure you meet every deadline and correctly declare all necessary data, guaranteeing 100% legal conformity.

Don’t risk your market access in Germany and the broader EU. The regulations are clear, and enforcement is strict. Readers who have not yet taken action should contact Deutsche Recycling immediately to comply with the regulations as quickly as possible. Let us handle the complexities of compliance so you can focus on your core business. Contact us today for a consultation and secure your compliance.