The German Packaging Act (VerpackG) came into force on January 1, 2019, implementing the EU’s Packaging Waste Directive. It mandates that any company placing packaging on the German market must contribute to the cost of its collection and recycling. This law applies to all B2C sales, with no minimum sales thresholds or quantity exemptions.

Since July 1, 2022, the obligations have become even stricter, extending to fulfillment service providers and online marketplaces. These platforms are now legally required to verify that their sellers are compliant, creating an immediate enforcement mechanism. If you are not registered, you face an instant sales ban on platforms like Amazon and eBay.

The law covers all packaging components, including product packaging, shipping boxes, filling materials, and tape. Every online retailer, from small sellers to large enterprises, must act now to avoid penalties. The next section details the two critical steps you must complete.

To legally sell in Germany, you must complete a two-part process involving registration and licensing. These are not suggestions but mandatory requirements under German law, and failure to complete both can result in fines of up to €200,000. Here are the two essential actions you must take:

1. Register with the LUCID Packaging Register: You must register your company with the ‘Zentrale Stelle Verpackungsregister’ (ZSVR) in their public database, LUCID. This registration is free of charge and must be completed before your first sale.
2. Participate in a Dual System: After receiving your LUCID registration number, you must sign a contract with a licensed ‘dual system’ provider. You will pay fees based on the volume and material types of your packaging (e.g., paper, plastic, glass).
3. Report Your Data: You are required to report your licensed packaging volumes to both your dual system provider and the LUCID register. This ensures transparency across the entire system.
4. Appoint an Authorized Representative: Foreign companies without a German branch may need an authorized representative to handle these obligations.

Completing only one of these two steps does not constitute compliance. You can get help with German packaging law registration to ensure every step is handled correctly. With these registrations complete, you must understand the severe consequences of ignoring these duties.

Ignoring the VerpackG is a costly mistake with penalties enforced by German authorities. The ZSVR has reported over 20,000 suspected cases of administrative offenses since 2019, demonstrating active enforcement. Fines are tiered based on the specific violation.

A failure to register with LUCID can result in a fine of up to €100,000 per case. The more severe offense of not participating in a dual system to license your packaging carries a penalty of up to €200,000. Beyond fines, authorities can issue an immediate distribution ban on your products, halting all your sales in Germany.

Because the LUCID register is public, competitors can easily check your compliance status. German law allows competitors to issue costly cease-and-desist letters to non-compliant companies, a common practice that adds legal fees to your financial risk. A full EPR compliance solution is the most effective way to mitigate these risks. Now, let’s review a checklist to ensure you have covered all requirements.

To ensure your online shop is fully compliant, you must systematically address each requirement of the Packaging Act. This checklist covers the essential actions for any business shipping goods to German consumers. Following these steps is not just about avoiding fines; it is about securing your access to one of Europe’s largest e-commerce markets.

• Identify all packaging materials: Account for every component, including boxes, mailer bags, bubble wrap, tape, labels, and product packaging.
• Calculate annual packaging volumes: Accurately estimate the total weight of each material type (paper, plastic, glass, etc.) you will place on the German market in a calendar year.
• Complete LUCID Registration: Go to the ZSVR website and register your company to receive your unique EPR number.
• Contract with a Dual System: Choose a licensed provider and pay the fees for your calculated packaging volumes.
• Provide EPR Number to Marketplaces: Submit your LUCID registration number to every online platform (Amazon, eBay, etc.) where you sell.
• Plan for Annual Reporting: Prepare to submit your final packaging volume data for the previous year by the deadline.

This checklist for Verpackungsgesetz provides a clear path to compliance. Looking ahead, these national rules are part of a larger European movement toward sustainability.

The German VerpackG is a forerunner of broader European Union regulations. The new EU Packaging and Packaging Waste Regulation (PPWR) will create more harmonized rules across all 27 member states starting in 2026. This regulation aims to reduce packaging waste by 15% per capita by 2040 compared to 2018 levels.

Key changes under the PPWR include a ban on excessive empty space, with shipping packages limited to a maximum of 50% empty volume. Furthermore, all packaging placed on the EU market must be designed for recyclability by 2030. For e-commerce, the PPWR introduces reuse targets, requiring 10% of transport packaging to be reusable by 2030.

These upcoming changes mean that achieving compliance today is only the first step. Businesses must adopt a forward-looking strategy to adapt to a circular economy. To understand the German dual system is to prepare for Europe’s future. This evolving landscape makes expert guidance more valuable than ever.

Navigating the complexities of the VerpackG and the upcoming PPWR requires constant vigilance and expertise. For many online retailers, managing these regulatory tasks internally is a significant drain on resources, diverting focus from core business activities. A single oversight can lead to six-figure fines and a complete halt of German sales.

Partnering with a specialist like Deutsche Recycling removes this burden and guarantees 100% legal conformity. We handle every aspect of your EPR obligations, from initial LUCID registration and dual system licensing to accurate data reporting and ongoing monitoring of legislative changes. Our service ensures you can continue selling to over 83 million German customers without interruption.

Do not leave your market access to chance. The regulations are complex, and the consequences of failure are severe. You must act now to protect your business. Contact Deutsche Recycling today for a consultation and let our experts manage your environmental compliance, ensuring your online shop operates securely and legally in Germany and across the EU.