Foreign Sellers Must Comply with Germany’s Packaging Regulations

Foreign businesses looking to sell packaged goods in Germany must navigate a set of legal obligations under the country’s packaging law, known as VerpackG. This regulation applies to all foreign entities, regardless of their physical presence in Germany, as long as their products reach German consumers. Key requirements involve registration, participation in a dual system, and ongoing reporting, which are overseen by the Zentrale Stelle Verpackungsregister (ZSVR) through the public LUCID Packaging Register.

Registration in the LUCID Packaging Register

Any company that introduces packaged products to the German market for the first time must register in the LUCID Packaging Register before shipping goods. The term “producer” encompasses various roles, including manufacturers, importers, brand owners, and online retailers. Since 2022, registration is mandatory for all packaging types, including retail, shipment, industrial, and reusable formats. Upon registration, companies receive a unique LUCID number, which is publicly accessible. Operating without valid registration can lead to severe penalties, including potential bans on sales.

Participation in a Dual System

Foreign sellers must also determine if their packaging requires participation in a dual system, especially if it reaches private consumers, such as through household waste. Packaging that falls into this category must be licensed through a recognized dual system. This includes retail, grouped, and shipment packaging used in e-commerce deliveries. To comply, companies need to sign a system participation agreement with a dual-system operator and pay fees based on the material and volume of packaging entering the market. These fees are crucial for funding nationwide collection and recycling services.

For those selling through online marketplaces or fulfilment providers, it is important to note that these platforms are now obligated to verify compliance with the packaging regulations.

After registration and licensing, companies must report their packaging volumes. This data submission is required for both the selected dual system and the LUCID registry, with consistent figures across both platforms. The frequency of reporting depends on the contract with the system operator, and businesses can adjust their expected volumes throughout the year as needed. Larger companies may also need to submit a declaration of completeness—a verified statement detailing all packaging distributed in the previous calendar year—to demonstrate full compliance.

The VerpackG framework emphasizes producer responsibility, ensuring that those contributing to packaging waste also play a role in its recovery. Non-compliance is publicly recorded in the LUCID registry, which poses financial and reputational risks for businesses. Therefore, early registration and accurate reporting are crucial for any international company engaging in trade within Germany.

The information provided here is based on details from Packaging Gateway, a brand owned by GlobalData. This content is intended for informational purposes only and should not be interpreted as professional advice. Seeking expert guidance before making decisions based on this information is recommended.