The German Packaging Act (Verpackungsgesetz), effective since January 1, 2019, mandates that anyone placing packaged goods on the German market must finance their recycling. This law applies to every online retailer, including small shops and international sellers, from the very first package sent. It covers all packaging components, including boxes, filling materials, and tape, that end up with the German consumer. The goal is to increase recycling rates and reduce waste, a key part of Germany’s circular economy strategy. Many small businesses mistakenly believe they are exempt due to their size, but there are no minimum sales thresholds. The law’s enforcement is strict, with online marketplaces now required to verify compliance, creating an urgent need for action. Understanding these rules is the first step toward securing your access to one of Europe’s largest e-commerce markets. This leads directly to the specific actions you must take.

Achieving Verpackungsgesetz compliance for small online shops involves three non-negotiable steps. You must complete these before any of your products are shipped to German buyers. Failure to do so constitutes a legal violation with significant consequences. Here are your required actions:

• 1. Register with the LUCID Packaging Register: Your first action is to register your company with the ZSVR (Zentrale Stelle Verpackungsregister) in the public LUCID database. This registration is free and provides you with a unique EPR number.
• 2. Participate in a Dual System: You must sign a licensing agreement with a state-approved recycling company, known as a dual system. This financially contributes to the collection and recycling of your packaging materials across Germany.
• 3. Report Your Packaging Volumes: You are required to report the exact volumes and material types of packaging you’ve licensed with your dual system to the LUCID register. This data must match what you report to your system provider.

Completing only one or two of these steps does not equal compliance; all three are mandatory. Get expert help with your German packaging law registration to ensure every step is correct. Once registered, you must select a partner to handle the physical recycling process.

Before anything else, you must complete your LUCID registration, a process managed by the ZSVR. This is a foundational requirement for Verpackungsgesetz compliance for small online shops and must be done by the business owner themselves. The registration is free of charge and done entirely online. You will need to provide your company details, contact information, VAT or taxpayer ID, and a list of all brand names you ship to Germany. Once submitted, you receive an activation link that must be used within 24 hours. Your registration makes your company publicly visible in the LUCID database, allowing authorities and marketplaces to verify your compliance status instantly. This transparency is a core feature of the law, designed to identify non-compliant sellers quickly. A complete LUCID profile is your first ticket to legal operation in Germany, as detailed in our checklist for LUCID registration. With your number secured, the next step is to license your packaging volumes.

After receiving your LUCID number, you must license your packaging volumes with a dual system. These are the companies responsible for organizing the nationwide collection, sorting, and recycling of packaging waste from consumers. Your license fee pays for this service, fulfilling the ‘Extended Producer Responsibility’ (EPR) principle. There are currently 11 approved dual systems in Germany you can partner with. The cost of your license depends on the weight and type of materials you use, such as cardboard, plastic, and glass. There is no minimum quantity; you must license your packaging from the very first gram. Choosing the right partner is crucial for cost-effectiveness and reliable service. For guidance, see our article on how to choose a dual system. The final mandatory step is to ensure your reported data is accurate and consistent.

The final pillar of compliance is accurate and consistent data reporting. You must report the packaging volumes you’ve licensed to both your chosen dual system and the LUCID register. These two data sets must be identical. Any discrepancy can trigger an investigation by German authorities. For most small businesses, this is an annual requirement. However, larger companies exceeding certain thresholds (e.g., 50 tonnes of paper/cardboard) must submit a more detailed ‘declaration of completeness’. Even a small error in reporting can be interpreted as non-compliance, risking fines up to €10,000 for data-related offenses alone. This underscores the need for meticulous record-keeping of all packaging materials shipped throughout the year. Managing these ongoing duties is where many businesses falter, highlighting the need for a robust compliance strategy.

Ignoring the Verpackungsgesetz is a costly mistake with consequences that can halt your German operations entirely. Authorities can issue fines of up to €200,000 for failing to participate in a dual system. Failure to register in LUCID can result in penalties of up to €100,000 per case. Beyond fines, you face an immediate sales ban, as marketplaces like Amazon and Etsy are legally required to block non-compliant sellers. Since the LUCID register is public, competitors can also easily identify and report non-compliant businesses, leading to costly legal challenges. The ZSVR reported over 20,000 cases of administrative offenses since 2019, showing active enforcement. You must act now to avoid EPR fines. The risks are simply too high to ignore, making a proactive solution essential.

Navigating the complexities of Verpackungsgesetz compliance for small online shops demands time and expertise that you need for your core business. This is why partnering with an expert is the most effective strategy. Deutsche Recycling offers a full EPR compliance solution designed to handle these obligations for you. We manage your LUCID registration, secure your dual system license, and ensure your data reporting is flawless and on time. Our service guarantees 100% legal conformity, protecting you from fines and sales prohibitions. By entrusting us with your compliance, you save dozens of administrative hours per year. Don’t let regulatory burdens block your access to the German market. The law requires you to act now. Contact Deutsche Recycling today for an individual consultation and ensure your business is fully compliant as quickly as possible.