Germany’s VerpackG affects every company acting as an ‘initial distributor’ of packaged goods to German consumers. This law, in effect since January 1, 2019, replaced the previous Packaging Ordinance and established a much stricter enforcement framework. It mandates that any business, from global corporations to small online shops, must participate in a dual system to fund the collection and recycling of their packaging materials. There are no minimum thresholds; every single piece of packaging must be licensed. The core principle is Extended Producer Responsibility (EPR), which shifts the disposal cost to the producer. This framework is crucial for anyone looking into the German Packaging Act. These regulations set the stage for even broader European rules.

Compliance with the German packaging and packaging waste regulation hinges on three non-negotiable duties. Failure in any one area can halt your German sales operations entirely. Since July 2022, online marketplaces like Amazon are legally required to verify your compliance, making these steps more critical than ever. You must act now to avoid being delisted.

Here are the essential requirements:

• LUCID Registration: Before placing any product on the market, you must register your company with the Central Agency Packaging Register (ZSVR), known as the LUCID portal, to receive your unique EPR number.
• System Participation: You must sign a contract with a state-approved dual system provider, paying a fee to license your annual packaging volumes and material types.
• Data Reporting: You are required to regularly report your licensed packaging volumes and the name of your dual system to the LUCID register, ensuring full transparency.

These obligations form the backbone of the dual system framework and are strictly enforced.

The new EU Packaging and Packaging Waste Regulation (PPWR) will replace the existing directive, creating a single, harmonized law across all 27 member states. This regulation enters into force in February 2025 and becomes fully binding after an 18-month transition period, by August 2026. It aims to tackle the 180 kg of packaging waste generated per person annually in the EU. The PPWR introduces ambitious waste reduction targets: a 5% cut by 2030, 10% by 2035, and 15% by 2040, compared to 2018 levels. For businesses, this means the compliance standards currently seen in Germany will become the EU baseline. You must prepare for these changes today. This new packaging waste regulation will impact your entire EU strategy.

The PPWR introduces several new, specific requirements that demand immediate attention from producers and distributors. By 2030, all packaging on the EU market must be designed for recycling. Furthermore, the regulation mandates minimum recycled content for plastic packaging, starting with a 30% requirement for certain PET packaging. A significant operational change is the rule to minimize empty space; e-commerce and transport packaging must not exceed a 50% empty space ratio by 2030. These new rules on extended producer responsibility are comprehensive. Preparing for these changes now is essential for uninterrupted market access.

Ignoring the German packaging and packaging waste regulation carries severe financial and operational consequences. Authorities can levy fines of up to €200,000 for each violation, such as failing to register with LUCID or not participating in a dual system. Beyond fines, companies face immediate sales bans, effectively cutting off access to the German market. Competitors can also issue legal warnings, leading to costly civil proceedings. Since 2022, fulfillment providers are prohibited from storing or shipping goods for non-compliant merchants, adding another layer of enforcement. These increasing warning letters show the seriousness of the regulations.

For international online retailers, the German Packaging Act presents unique challenges. The law applies to any company shipping to German end-consumers, regardless of where the business is based. This means even a small business outside Germany must comply fully with LUCID registration and dual system licensing. Marketplaces like eBay and Amazon now require sellers to provide a valid LUCID ID to continue selling to Germany. Many international sellers overlook that they are the ‘initial distributor’ responsible for compliance. Understanding your take-back obligation is the first step toward securing your business. This complexity requires expert guidance to navigate successfully.

Navigating the complexities of the VerpackG and the upcoming PPWR is a significant burden for any business. The legal requirements are intricate, and the risk of non-compliance is too high to manage alone. Deutsche Recycling offers a complete service to ensure you are 100% legally compliant. We handle every aspect of your obligations, from LUCID registration to dual system licensing and data reporting. Our experts manage the entire process, freeing you to focus on your core business operations. For a complete overview of your responsibilities, review our guide on packaging regulation. Don’t wait for a warning letter or a sales ban to take action.

The regulatory environment for packaging is only becoming stricter. The transition to the EU-wide PPWR means that the compliance requirements you face in Germany today will soon apply across Europe. Proactive compliance is the only way to protect your business from disruption. Waiting until deadlines pass or enforcement actions begin is a costly mistake. By partnering with an expert, you ensure that your business meets all current and future obligations seamlessly. Even small businesses need a packaging license to operate legally. The time to secure your market access and achieve full compliance is now. Contact Deutsche Recycling today for an individual consultation and let our experts handle the complexities for you. This is the final step to ensure your business is secure.