The Verpackungsgesetz (VerpackG) applies to any company first placing packaging on the German market commercially. This ‘first distributor’ principle makes you, the international online seller, directly responsible for every shipping box, roll of tape, and piece of product packaging you send to German consumers. There are no exceptions or minimum volume thresholds; your obligation begins with the very first item you ship. The law covers all packaging materials that typically end up in private household waste, which includes nearly all e-commerce packaging. Understanding this responsibility is the first of 3 critical steps toward compliance. You must act now to avoid penalties that can reach €200,000 for certain violations. This initial recognition of your role is fundamental before you can take further action.

Complying with the Verpackungsgesetz involves three non-negotiable actions that must be completed before your products reach Germany. Overlooking even one of these steps results in immediate non-compliance and potential sales bans from marketplaces like Amazon. These platforms are now legally required to verify your compliance status, making these actions more critical than ever. The entire process ensures you contribute to Germany’s recycling targets, which aim for rates as high as 90% for materials like ferrous metals and glass. Here is the 3-step process you must follow:
1. Register with LUCID: You must register your company in the LUCID Packaging Register, which is managed by the Central Agency Packaging Register (ZSVR). This registration is free of charge and provides you with a unique EPR number.
2. Participate in a Dual System: You must sign a contract with a licensed ‘dual system’ provider. This step involves paying licensing fees for the packaging materials (paper, plastic, etc.) you will place on the market for the upcoming year.
3. Report Your Data: You are required to report your packaging volumes and your dual system partner to the LUCID register. This data must match the information you provided to your dual system precisely.
Completing these steps is not a one-time task; data reporting is an ongoing obligation. For a detailed breakdown, see our checklist for LUCID registration.

A core component of compliance is accurately forecasting and licensing your annual packaging volumes. Your licensing fee, paid to your chosen dual system, is calculated based on the weight of each material type you use—for example, cardboard, plastic, and glass. An incorrect calculation can lead to under-licensing, which is a form of non-compliance with penalties up to €10,000. Many sellers underestimate the scope of reportable packaging, which must include all components. Here are the materials you must account for:
* Primary Packaging: The container that directly holds your product (e.g., a bottle, jar, or product box).
* Secondary Packaging: Any additional material used to group products, such as a plastic wrap around multiple items.
* Shipping Packaging: The outer box or mailer bag used for transport to the customer.
* Filling and Cushioning: All void-fill materials like bubble wrap, air pillows, or packing peanuts.
* Sealing Materials: Adhesive tapes, straps, and labels applied to the package.
Failing to account for just 1 kilogram of material can put your business at risk. This detailed calculation is essential for maintaining your legal standing in the market. Learn more about how to license your shipping boxes correctly.

The consequences for ignoring the Verpackungsgesetz are severe and enforced without exception. Fines can be as high as €200,000 for failing to participate in a dual system. Even a simple failure to register in LUCID can trigger fines of up to €10,000 and, more critically, an immediate prohibition on all sales in Germany. Marketplaces like Amazon and eBay now automatically block listings from non-compliant sellers, meaning your access to millions of customers can be cut off overnight. These platforms actively check for a valid LUCID registration number for all sellers shipping to Germany. Without it, your business operations can come to a complete halt. The financial and operational risks are too significant to ignore, making immediate action a business necessity. You can get a complete guide to these laws to better understand the risks.

The German Packaging Act is not an isolated piece of legislation; it is part of a broader EU strategy to enforce Extended Producer Responsibility (EPR). The new EU Packaging and Packaging Waste Regulation (PPWR) will further harmonize these rules, making compliance a prerequisite for accessing the entire EU single market. By complying with the Verpackungsgesetz now, you are future-proofing your business against upcoming EU-wide regulations. The directive requires that all packaging on the EU market be recyclable in an economically viable way by 2030. Taking action today is not just about Germany; it is about securing your long-term position in the European market. Waiting to act will only increase complexity and risk. For help with your obligations, you should explore our solutions.

Navigating the complexities of the Verpackungsgesetz requires expertise and constant attention, diverting resources from your core business. Deutsche Recycling offers a comprehensive, full-service solution designed to manage 100% of your EPR obligations in Germany. We handle every step of the process, from initial registration to ongoing data reporting, ensuring you remain fully compliant at all times. Our service eliminates the risk of fines and sales bans, providing you with complete peace of mind. For international sellers, managing these requirements from abroad can be a significant burden. Let our experts handle it for you. We provide:
* Complete LUCID registration and management.
* Selection and contracting of a cost-effective dual system.
* Accurate calculation and reporting of all your packaging volumes.
* Ongoing monitoring of legislative changes to ensure you are always compliant.
If you have not yet taken action, it is imperative to contact Deutsche Recycling immediately. We can expedite the process to help you comply with all regulations as quickly as possible and secure your business in the German market. Manage your German EPR obligations with an expert partner.