The Verpackungsgesetz applies to all companies placing packaged goods on the German market commercially for the first time. This includes manufacturers, importers, online retailers, and distributors, regardless of where the company is based. The law covers all packaging that typically ends up as waste with private final consumers, which includes product, shipping, and service packaging. There are no minimum sales thresholds; obligations begin with the very first item shipped. If your business fits this profile, you must take immediate action to comply with the law. Understanding your role as an ‘initial distributor’ is the first step toward meeting your legal duties. This prepares you for the specific registration requirements that follow.

Your first actionable step for Verpackungsgesetz compliance is registering with the LUCID Packaging Register, managed by the Zentrale Stelle Verpackungsregister (ZSVR). This registration is free of charge but absolutely mandatory before any of your goods enter the German market. During registration, you must provide your company details and the brand names of the products you sell. Since July 2022, online marketplaces are required to verify your LUCID registration, making it impossible to sell without one. Failure to register can result in immediate sales prohibitions. You can find detailed instructions and checklists to streamline this process. A checklist for LUCID registration ensures you have all necessary information ready. Once registered, you receive a unique EPR number, which is essential for the next step: system participation.

After registering in LUCID, you must license your packaging volumes with a state-approved dual system. This fulfills your extended producer responsibility (EPR) by paying for the collection and recycling of your packaging waste across Germany. You must have a valid agreement with a dual system before your products are sold. The fees you pay are calculated based on the weight and material type of your packaging, typically amounting to a few cents per kilogram. It is critical to choose a reliable partner for this step. Here are the key requirements for this step:

• Select one of the officially approved dual systems.
• Sign a legally binding contract for system participation.
• Provide accurate forecasts of your annual packaging volumes per material type (e.g., paper, plastic, glass).
• Pay the licensing fees based on the provided data.

This system participation is a core element of what is required for Verpackungsgesetz compliance. Your choice of a German dual system partner is crucial for ongoing compliance, which leads to your reporting duties.

Compliance does not end with registration and licensing; it requires continuous data reporting. You must report the exact volumes of packaging you placed on the market to two separate entities: your chosen dual system and the LUCID register. These reports must be identical and submitted regularly, typically on an annual or quarterly basis, depending on your agreement. Any discrepancy between the two reports can trigger an investigation by the ZSVR. For companies exceeding certain volume thresholds—80,000 kg of glass, 50,000 kg of paper, or 30,000 kg of plastics—an annual Declaration of Completeness is also required by May 15th. This declaration must be audited and submitted by a registered expert. These reporting duties are critical for maintaining your legal status in the German market.

The consequences of non-compliance with the Verpackungsgesetz are severe and can halt your business operations in Germany. Authorities can impose fines of up to €200,000 for failing to register or participate in a dual system. They can also issue written warnings, which often come with fees of several hundred euros. Furthermore, you face an immediate prohibition on selling your products in Germany, and authorities can even confiscate your goods. Since July 2022, fulfillment service providers are also barred from working with non-compliant companies. You can get help with German packaging law to prevent these outcomes. The only way to operate securely is to address these requirements proactively. Now is the time to take decisive action.

The requirements of the German Packaging Act are complex and non-negotiable. The time to act is now. Every day you operate without full compliance, your business is exposed to significant legal and financial risks. Waiting for a warning letter is not a viable strategy; you must be proactive. Deutsche Recycling offers a complete service to manage all your Verpackungsgesetz obligations. We handle your LUCID registration, secure your dual system participation, and manage all your data reporting. By partnering with us, you achieve 100% legal certainty and can focus on your core business. Do not delay any longer. Contact Deutsche Recycling today for an individual consultation and ensure your business is fully compliant with German law.