As an online retailer in Germany and Europe, you cannot avoid the topic of packaging. Each country has different regulations, quantity thresholds, and labeling requirements – so it’s worthwhile to know the most important obligations. Here you get an overview of the German Packaging Act and learn how you can ensure legal compliance.
The German Packaging Act (VerpackG) at a Glance
If you supply packaged products to private end consumers in Germany, you are obliged to license your packaging – from the very first unit placed on the market, regardless of the material.
If you ship packaged products to private end consumers in Germany, you are affected by the Packaging Act (VerpackG). All companies that put product, shipping, or service packaging on the market for the first time to private end customers must license it in the interest of environmental protection. It does not matter if the packaging is plastic, paper, or glass. The obligation applies from the first piece placed on the market and is independent of volume and material. So-called packaging subject to system participation – i.e., packaging handed over to private end consumers – must be registered with the Central Packaging Register (ZSVR) in the LUCID producer register. The ZSVR acts as the supervisory authority.
As a retailer or manufacturer, you are responsible, as part of your extended producer responsibility (Extended Producer Responsibility), for taking back, collecting, sorting, and recycling the packaging you place on the market. To fulfill this obligation, you conclude a license agreement with a dual system, which handles these tasks using the license fees you pay.
Fig. 1: Own illustration
The Packaging Act aims to ensure high rates of packaging waste recycling, conserve valuable raw materials, and provide incentives to reduce packaging waste and promote more environmentally friendly packaging.
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Licensing, Registration, and Data Reporting: What You Need to Know in Germany
To sell legally, you must fulfill three obligations even before you place any packaging on the market for the first time:
- Conclude your license agreement. License the quantities of packaging you expect to put on the market over the course of a year with a dual system such as Interzero Recycling Alliance via lizenzero.de. The quantities may initially be estimated and adjusted during the year. After concluding the contract, you will receive a system participation confirmation from your dual system.
- Register with the ZSVR in the LUCID reporting register. This registration is free of charge.
- Report your licensed quantities and the name of your dual system in LUCID. You will receive a registration number that you must provide both to your dual system and as proof of lawful sales on online marketplaces.
Once you have completed these obligations, only minor tasks remain each year. By May 15 each year, you must submit your annual final quantity report for the previous year to your dual system and in LUCID. By December 31, you can also submit your quantity forecast for the following year as the so-called initial planned quantity report.
Fig. 2: Own illustration
Consequences of Non-Compliance with the Packaging Act
If you do not license your sales packaging, you risk warnings, fines of up to 200,000 euros, and distribution bans. Since July 1, 2022, operators of electronic marketplaces are required to check compliance with the Packaging Act. As a seller, you are directly obliged to provide proof of licensing. Your LUCID registration number and, if applicable, the system participation confirmation from your dual system serve as proof.
Fig. 3: Own illustration
Focus: Europe – What Needs to Be Considered Where?
Based on the EU Packaging Directive, each EU country is currently implementing its own packaging regulations and laws – as the Packaging Act (VerpackG) is implemented in Germany. All share the goal of reducing packaging waste, promoting recycling, and conserving resources. Since there is no central contact point and information is often only available in the respective national language, licensing in Europe may initially seem complex.
As an online retailer, you are faced with the task of keeping track of the different licensing and labeling obligations for your packaging. Together with our partner LIZENZERO.EU, we have summarized the most important to-dos for B2C retailers for some relevant export countries.
The Triman Logo and the Prevention Plan in France
In France, all sales packaging is subject to a licensing requirement. The costs are calculated in consumption units. Very small distributors with up to 10,000 consumption units per year benefit from a flat rate, and for quantities over 500,000 units per year, a detailed reporting procedure applies. In addition, there is a labeling requirement: your packaging must bear the Triman logo as well as relevant sorting instructions. You must also submit a prevention plan outlining how you reduce the environmental impact of your packaging.
Regulations in the United Kingdom
A licensing obligation applies to companies that have a branch in the UK, achieve an annual turnover of at least £1,000,000, and whose packaging has a minimum weight of 25 tonnes. In addition to licence fees, there is also a registration fee and a membership contribution for the licensing system. Similar to Germany, there is no labeling requirement on the packaging.
How do I label my packaging in Italy?
In addition to the annual licensing requirement for companies with an Italian branch, there is an obligation for environmental labeling in Italy. All packaging materials must be labeled regardless of the licensing requirement. You must mark your packaging materials with clear disposal instructions, indicate composition using alphanumeric codes, and provide understandable separation instructions in Italian.
What do I need to consider as an online retailer in Austria?
If you ship goods to or within Austria, you are required to license all household packaging placed on the market with a recycling system. If your business is not based in Austria, appointing an authorized representative is also required. There is no labeling obligation for packaging, but you must provide information about compliance with the packaging licensing—for example, with a note on the delivery slip. For annual quantities of up to 1,500 kg, you report once a year as a flat-rate discharge; above that, you report monthly or quarterly.
The Authorized Representative in Spain
If you place household packaging on the market in Spain, you are required to obtain a license. If your company also has a branch or tax number in Spain, registration is mandatory for all types of packaging without a de minimis threshold—regardless of the material. Foreign companies are also required to appoint an authorized representative for registration and quantity reporting. In addition to the licensing fees, costs arise for the authorized representative as well as membership fees for the recycling system. Unlike in France and Italy, there are no packaging labeling requirements in Spain.
Our partner LIZENZERO
With LIZENZERO, you as a retailer have a strong partner for Europe-wide packaging licensing by your side. lizenzero.de offers many years of expertise and an on-demand customer account, providing comprehensive convenience for packaging licensing in Germany starting from just €39 per year. Free additional services such as a quantity download for LUCID, a resource protection certificate, and personal consultation complete the service.
With the code “VALUEZON10″* you save 10% when signing your license agreement for Germany on lizenzero.de.
Do you need support with licensing in your export country? Our partner also helps you at lizenzero.eu with European packaging licensing and takes care of all requirements from start to finish as part of the licensing service.
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*Valid until 31.12.2024. Discount applies to net goods value. No cash payout possible. One coupon per order and customer. Cannot be combined with other discount promotions. Not redeemable retroactively. Legal recourse is excluded.
