The registration and labeling requirements are based on the Packaging Act, which has been in force since January 1, 2019. The aim is to achieve a higher recycling rate. Manufacturers, distributors, and importers must register with the Central Agency Packaging Register and report packaging quantities. The law applies to everyone who places packaging on the market.
What is the aim of the new Packaging Act?
The Packaging Act ( pursues clear environmental goals and sets guidelines for the handling of packaging.
- The law implements European environmental objectives (Directive 94/62/EC).
- The aim is to prevent environmental damage caused by packaging.
- It applies to all packaging, with a few exceptions.
- Manufacturers and retailers should avoid packaging wherever possible.
- If packaging is necessary, it should be reusable or recyclable.
- Reusable beverage packaging is preferred.
Service packaging: Special rules
Service packaging is filled directly by the seller on site. The distributor can take over system participation for this packaging and does not need to register separately. Packaging without system participation may not be sold. Registration and labeling in accordance with § 9 VerpackG create transparency and help those affected to comply with EU requirements.
Examples of service packaging:
- Disposable coffee cups
- Plastic bags
- Bread bags
What do these obligations mean?
In order to be able to identify the packaging material, the packaging must first be labeled. The manufacturer is obliged to specify the type of material and mass of the respective packaging. This is regulated in Annex 5 of the new Packaging Act. Labels other than those specified there are not permitted.
How does registration with the Central Agency Packaging Register (ZSVR) work?
The manufacturer must then register with the Central Agency Packaging Register (ZSVR). To do so, they can register online at https://www.verpackungsregister.org and submit their data there.
The following information must be provided during registration:
- Manufacturer’s contact details
- Name of the authorized representative
- Identification number and tax number of the manufacturer
- Brand name of the product with packaging
- Declaration regarding take-back obligations
- Declaration that the information provided is true
Information about the packaging must also be provided. This includes:
- Registration number
- Type of material and weight of the packaging
- Name of the waste disposal system
- Period of participation in the system
How do manufacturers fulfill their system participation obligation and what needs to be considered?
In order to fulfill their system participation obligation ( § 7 VerpackG), manufacturers must conclude a system participation agreement with a waste disposal company. The ZSVR checks the accuracy of the data by comparing it with the waste disposal company. Any changes to the data must be reported to the ZSVR immediately. After withdrawal from the market, the data will remain published for a further three years.
What deadlines must be observed?
Manufacturers must submit an annual declaration of completeness for the packaging placed on the market. This obligation applies until May 15 for the previous year and is regulated by the Packaging Act.
Important points regarding the declaration of completeness:
- Submission deadline: annually by May 15
- Information on all sales and outer packaging from the previous year
- Obligation applies in accordance with Section 11 (2) VerpackG
- Exemption for quantities below the following thresholds:
- Glass: less than 80,000 kg
- Paper, cardboard, carton: less than 50,000 kg
- Other materials: less than 30,000 kg (see Section 16 (2) VerpackG)
What are the consequences of non-compliance?
Manufacturers and distributors may only sell packaging subject to system participation if they are registered with the ZSVR. Otherwise, a sales ban applies. Violations are also punishable by fines of between €10,000 and €200,000 (§ 34 VerpackG).
Who is affected by the registration requirement in the packaging register?
All manufacturers are affected by the registration requirement, as are brand names when they place packaging on the market for the first time. All packaging is subject to system participation if it ends up as waste with a private end consumer.
How can consumers see which manufacturers are registered?
The LUCID online database allows consumers to see which manufacturers and brands are registered with the ZSVR. The database is intended to contribute to greater transparency for end consumers. If you are interested, you can register on the platform and gain access to the registers. LUCID publishes both manufacturer and auditor registers.
Do you have any further questions? Deutsche Recycling will be happy to support you with your obligations and advise you on all relevant matters. Benefit from our full service and save time and money.
FAQ: Labeling requirements for packaging materials
Do foreign companies without a registered office in Germany have to comply with the registration requirement when they deliver goods to Germany?
Foreign manufacturers and distributors who deliver packaging to Germany for the first time are also subject to the registration and labeling requirements for packaging materials. They must also appoint an authorized representative in Germany to take on the legal obligations.
How long do manufacturers have to keep their evidence and documents relating to system participation?
Manufacturers must keep all evidence and documentation relating to system participation for at least three years. This includes confirmation of registration, quantity reports, and contracts with dual systems.
Are manufacturers allowed to conclude multiple system participation contracts?
Yes, manufacturers can participate in multiple dual systems for their packaging. It is important that each packaging quantity is reported correctly and traceably and transferred to the respective system.
Is there any way to be exempted from the obligation to participate in the system?
No, there is generally no exemption from the obligation to participate in the system for packaging that is subject to system participation. Exceptions only apply to certain types of packaging, such as transport packaging, which is not generated by private end consumers. However, these are also subject to reporting and take-back obligations, but are not subject to system participation.
