The regulatory landscape for packaging is tightening across Europe, driven by the new Packaging and Packaging Waste Regulation (PPWR). This isn’t a minor update; it replaces the 1994 directive with legally binding rules for all 27 EU member states. The PPWR mandates that all packaging must be designed for recyclability by 2030 and sets waste reduction targets of 5% by 2030. For businesses selling in Germany, these EU-wide changes amplify the existing strictness of the German Packaging Act (VerpackG). Waiting to adapt is a risk that can result in immediate sales prohibitions. The time for observation is over; you must take action now to align your operations with these new legal standards. This new reality makes understanding VerpackG compliance requirements more urgent than ever.

Compliance with the VerpackG rests on three fundamental obligations that apply from the very first package you place on the German market. There are no de minimis limits, meaning even one shipment makes you responsible. Failing to complete any of these steps can halt your business activities in Germany. The entire process is designed to ensure producers finance the recycling of the packaging they introduce. Here are the three non-negotiable duties for every company: 1. LUCID Registration: Before any packaged goods are sold, you must register with the Central Agency Packaging Register (ZSVR) in their public database, LUCID. 2. System Participation: You must sign a contract with a state-approved dual system operator to handle the collection and recycling of your packaging waste. 3. Data Reporting: You are required to report your packaging volumes to both your chosen dual system and the LUCID register simultaneously. Many companies overlook that registration must be completed before the first item is shipped. These duties form a closed loop of responsibility, and the next step is to correctly calculate the data for your reports.

Accurate data reporting is the most complex part of your ongoing obligations. The volumes you report to your dual system must exactly match the volumes you report in the LUCID portal. These reports are typically submitted on a monthly, quarterly, or annual basis, depending on your contract with the dual system. Your reports must break down packaging by material type and mass, specified in kilograms. You will need to submit two main types of reports during the year. For help, you can review how to declare packaging materials correctly. The two primary report types are: 1. Initial Planned Volume Report: This is a forecast of the packaging volumes you expect to place on the market for the upcoming calendar year. It must be submitted by the end of the current year. 2. Year-End Volume Report: This report details the actual volumes you placed on the market during the past year. The firm deadline for this report is May 15th of the following year. A 1-kilogram error in reporting can be considered a compliance violation. Ensuring precision in these reports is vital, especially for producers handling large volumes who face additional verification duties.

If your company places large quantities of packaging onto the German market, you have an additional, stringent reporting requirement: the Declaration of Completeness (Vollständigkeitserklärung). This is a formal declaration of all packaging you introduced in the previous calendar year, and it must be audited by a registered expert. The deadline for submitting this audited declaration to the LUCID register is May 15th each year, and this deadline cannot be extended. Failure to submit on time is an administrative offense that can trigger significant fines. You are required to file a Declaration of Completeness if you exceed any of the following thresholds in a calendar year: 80,000 kilograms of Glass 50,000 kilograms of Paper, Paperboard, or Cardboard 30,000 kilograms of Lightweight Packaging (a combined total of plastics, aluminum, ferrous metals, and other composites) Even if you do not meet these thresholds, the ZSVR can still require you to submit a Declaration of Completeness at any time. This underscores the need for meticulous record-keeping, which a partner can help manage through a yearly packaging license.

Navigating the complexities of the VerpackG and the new PPWR is a significant administrative burden that distracts from your core business. The risk of errors, missed deadlines, and fines up to €200,000 is substantial. Partnering with an expert service provider like Deutsche Recycling removes this burden and guarantees 100% legal conformity. We manage your registration, system participation, and all data reporting requirements, ensuring you meet every obligation on time. Don’t leave your market access to chance. The regulations are in force now, and immediate action is required. If you have not yet secured your compliance for Germany, you must act quickly. Contact Deutsche Recycling today for a consultation to ensure your business is fully protected. By working with us, you can be confident you are fulfilling all your duties under German and EU law.