German Packaging Act (VerpackG) / Licensing of Packaging

On January 1, 2019, the new German Packaging Act (VerpackG) came into effect, replacing the previously valid 5th amendment of the Packaging Ordinance (VerpackV). The Packaging Act regulates the placing on the market, return, and recycling of packaging as well as its financing. All manufacturers and distributors who fill packaging with goods and place it on the market for the first time—where such packaging typically ends up with private end consumers—are subject to obligations under this law (This law only applies to companies in Germany.).

Who is obligated to license packaging?

As a manufacturer or distributor, you are obligated if you:

• - use packaging for commercial purposes
• - place it on the market for the first time
• - pass it on to end consumers, where it typically becomes household waste

Private end consumers include not only households, but also equivalent sources such as restaurants, craft businesses, and agricultural operations with packaging waste volumes not exceeding 1.1 m³, collected at regular household intervals.

Which types of packaging are subject to licensing?

All packaging that typically becomes waste at a private end consumer or a comparable source must be licensed. According to the Packaging Act, packaging includes all components that protect, contain, bundle, or transport a product. The law distinguishes between the following categories:

Sales Packaging

Sales packaging is packaging typically offered to end consumers as a sales unit comprising the product and the packaging. It also includes:

Service Packaging

Service packaging is filled with goods at the point of sale by the distributor and handed over directly to the end consumer. This includes items like bread bags, carrier bags, coffee cups, burger boxes, snack trays, french fry bags, disposable tableware, and more.

Shipping Packaging

Shipping packaging enables or supports the shipment of goods to end consumers, as defined in § 3 para. 1 no. 1b VerpackG. All components used in the shipment—such as shipping boxes, packing slips, adhesive tape, filling material, etc.—are subject to system participation.

Exceptions

Exceptions to the obligations under the Packaging Act include:
1. According to § 12 VerpackG: Reusable packaging, one-way packaging subject to a deposit, packaging not intended for end consumers, and packaging for hazardous materials.
2. As per Annex 1 to § 3 para. 1 of VerpackG: Items such as stirrers and disposable cutlery are not considered packaging.
3. Transport packaging, which typically does not end up with the end consumer, is also not subject to system participation.

What must affected manufacturers or distributors do?

1. LICENSE

To license your packaging, register with a dual system provider of your choice.

2. REGISTER

The obligation to license packaging has existed since 1991 with the Packaging Ordinance. The new Packaging Act introduced a mandatory registration in the public register “LUCID”. All companies placing packaging subject to system participation on the market must register there. This proves compliance and is monitored by the Central Packaging Register Foundation (“Zentrale Stelle Verpackungsregister”). The register is publicly accessible—customers, competitors, and lawyers can verify which companies are registered and which are not.

3. CONFIRM

Quantities reported monthly or quarterly must be reconciled at the beginning of the following year with actual quantities placed on the market. The final annual volume must then be reported to the dual system and to the Central Packaging Register.

Our Service for You

The obligation to participate in the system cannot be transferred to other companies, except in the case of service packaging. The law aims to support small businesses (e.g. snack bars, bakers, artisans) by allowing them to delegate the licensing to upstream suppliers.

You can either license your packaging yourself through an approved dual system provider, or you can delegate pre-licensing to us. On every product page of a packaging subject to licensing, you have the option to add licensing directly to your order. In this case, we pay the necessary licensing fees on your behalf, and you will receive proof on your invoice. This way, you fulfill all legal obligations (registration, licensing, volume reporting) without any additional effort.

We are registered under the LUCID number DE3444507958339 and report the packaging volumes accordingly. If you use our service, you do not need a separate contract with a dual system provider, nor do you need to register or report anything yourself for the packaging purchased from us.

More Information, FAQs, and Links

Detailed information about the Packaging Act can be found at the following links:

Instructional videos from the Central Authority

FAQs by the Central Authority / Packaging Register

List of approved dual system providers

Full text of the Packaging Act (PDF)

Note: This information does not constitute legal advice, and we do not guarantee completeness or accuracy.