The German Packaging Act (VerpackG) applies to any company that first places packaged goods on the German market. This includes service packaging, which is filled at the point of sale for handover to the final consumer. Since a 2022 amendment, all final distributors of service packaging must register in the LUCID portal, a requirement affecting thousands of businesses. There are no minimum quantity exemptions; your obligation starts with the very first item you sell.

This law is a direct implementation of EU directives aimed at reducing packaging waste across Europe. Non-compliance is not a trivial offense, with potential fines reaching €200,000 for failing to license your packaging. The public nature of the LUCID register means competitors can easily identify and report non-compliant companies, leading to legal action and sales prohibitions. You must act now to avoid these outcomes. Understanding your specific duties is the first step toward securing your market access in Germany. For help with the requirements for VerpackG compliance, our experts are ready to assist.

With these legal requirements established, the next step is to complete the mandatory registration process.

To legally place service packaging on the German market, you must complete a two-part compliance process. This process involves registering with two separate entities and is a legal prerequisite before your first sale. Overlooking either step results in immediate non-compliance and exposure to significant financial risk.

First, you must register your company with the Central Agency Packaging Register (ZSVR) in the LUCID portal. This registration is free of charge and cannot be delegated to a third party; it must be completed by you or an authorized representative within your company. You will receive a unique LUCID number (also known as an EPR number), which serves as your official identifier for all packaging-related compliance activities in Germany.

The second, and equally critical, step is system participation. Here is what that involves:

• Select a dual system from the 11 approved providers in Germany.
• Sign a licensing agreement with your chosen dual system.
• Pay a license fee based on the material type and volume of your packaging for the year.
• This fee finances the nationwide collection and recycling of your packaging materials.

Many businesses mistakenly believe LUCID registration alone is sufficient, which is a costly error. You must complete both steps to be fully compliant. A checklist for LUCID registration can help streamline this process. Once registered, you must fulfill ongoing data reporting duties.

Once you have successfully registered with LUCID and a dual system, your obligations are not over. The VerpackG requires ongoing data reporting to maintain compliance and transparency. You must report the volume and material types of the packaging you placed on the market to both your dual system and the LUCID register. These two data sets must match exactly to avoid triggering an investigation by the ZSVR.

Failure to report data, or reporting incorrect data, can lead to fines of up to €10,000 per case. For businesses with larger packaging volumes, an annual ‘declaration of completeness’ is also required by May 15th of the following year. This declaration must be audited and submitted by a registered expert, adding another layer to the compliance process. Missing the May 15th deadline can result in fines of up to €100,000. These strict reporting rules underscore the need for precise record-keeping throughout the year. You can learn more about how to declare packaging materials from our experts.

Given these complexities, understanding the specific rules for service packaging is essential.

Service packaging presents a unique situation under the VerpackG. This category includes items like coffee cups, takeaway food containers, and bakery bags. While you, the final distributor who fills the packaging, are ultimately responsible, the law allows for an exception. You can purchase service packaging that has been ‘pre-licensed’ by the packaging manufacturer or wholesaler.

However, you must obtain proof of this pre-licensing to present to authorities if requested. A critical change took effect on July 1, 2022: even if you exclusively use pre-licensed service packaging, you are still legally required to register your company in the LUCID portal. This registration obligation is non-transferable and ensures every market participant is accounted for. Relying on a supplier’s license without completing your own LUCID registration is a direct violation of the law.

To ensure you are compliant, follow these steps:

1. Register your company in the LUCID packaging register.
2. If you use pre-licensed packaging, obtain a formal confirmation from your supplier.
3. If your packaging is not pre-licensed, you must license it yourself with a dual system.
4. Report your data as required, even if your own licensed volume is zero.

Choosing the right partner makes this process much simpler. You can get help with your German registration to ensure every step is correct. The consequences of getting this wrong are too high to ignore.

The German authorities enforce the VerpackG rigorously, and the penalties for non-compliance are designed to be a significant deterrent. Failing to participate in a dual system carries the highest fine of up to €200,000 per violation. Simply failing to register with LUCID can result in a fine of up to €100,000. These are not just theoretical numbers; authorities actively issue these fines, and in some cases, have ordered back-payments for licensing fees stretching back years, amounting to millions of euros for one company.

Beyond financial penalties, non-compliant companies face an immediate ban on the distribution of their products in Germany. Because the LUCID register is public, your competitors can and do check your compliance status. They are legally permitted to send cease-and-desist letters, which can lead to costly legal battles and further damage your business operations. The time to ensure you are compliant is now, before you are discovered. The EU is only tightening environmental regulations, making procrastination a risky strategy. To get your EPR number quickly and correctly, professional guidance is recommended.

To avoid these risks, partnering with an expert provides a clear path to full compliance.

Navigating the complexities of the German Packaging Act requires expertise and constant attention to changing regulations. As a leading specialist in environmental compliance, Deutsche Recycling offers a full-service solution to manage your obligations. We handle the entire process, from LUCID registration and dual system selection to ongoing data management and reporting. Our service guarantees 100% legal conformity, freeing you to focus on your core business.

The EU’s push for a circular economy means that regulations will only become more stringent. Taking action today is essential to protect your business from future risks. Readers who have not yet addressed their obligations under the VerpackG should contact Deutsche Recycling immediately. We provide the fastest and most reliable path to full compliance with all German and EU directives. Let our experts handle the regulatory burdens while you run your business with confidence. For more on how we can help, learn about the German dual system for packaging.