Foreign Businesses Must Navigate German Packaging Regulations

Foreign companies wishing to sell packaged goods in Germany must adhere to specific legal obligations under the country’s packaging law, known as VerpackG. These requirements apply even if the business has no physical presence in Germany, as long as its products reach German consumers. The regulations, which are aimed at promoting responsible packaging waste management, necessitate registration, system participation, and ongoing reporting to ensure compliance.

Mandatory Registration in the LUCID Packaging Register

Any entity that introduces packaged products to the German market must register with the LUCID Packaging Register prior to shipping goods. Under the law, a “producer” encompasses a variety of roles including manufacturer, importer, brand owner, and online retailer. Since January 1, 2022, this registration requirement has expanded to include all types of packaging, from retail and shipment packaging to industrial and reusable formats.

Upon successful registration, companies receive a unique LUCID number, which is publicly accessible. Operating without this valid registration can lead to significant penalties, including potential sales bans, underscoring the importance of compliance for international businesses.

Joining a Dual System for Consumer Packaging

Foreign sellers must assess whether their packaging is subject to system participation. If the packaging ultimately ends up as private waste—such as household refuse—it must be licensed through a recognized dual system. This requirement encompasses retail packaging, grouped packaging, and shipment packaging used in e-commerce.

To comply, companies must enter into a system participation agreement with a dual-system operator and pay fees that are determined by the type and volume of packaging they place on the market. These fees contribute to nationwide collection and recycling services. Notably, online marketplaces and fulfillment providers are now mandated to verify compliance from their sellers, adding another layer of responsibility for foreign companies.

Reporting Obligations and Compliance Monitoring

Once registered and licensed, businesses are required to report their packaging volumes. This data must be submitted to both the chosen dual system and to LUCID, with the figures needing to match across both reports. The frequency of reporting is dependent on the contract with the system operator, and businesses have the option to update expected volumes throughout the year if necessary.

Larger companies may also be obligated to file a declaration of completeness, which is an audited statement detailing all packaging distributed in the previous calendar year. This measure ensures that companies demonstrate full compliance with German packaging laws.

For foreign sellers, adherence to the VerpackG is not optional; it is a critical framework that promotes producer responsibility. It ensures that those contributing to packaging waste also take part in its recovery. Non-compliance is publicly visible in LUCID and can carry both financial and reputational risks. Therefore, early registration and precise reporting are essential steps for any international business seeking to trade in Germany.

The information provided in this article is based on guidelines from the Zentrale Stelle Verpackungsregister (ZSVR) and serves to inform businesses about their obligations under German law. Companies are encouraged to seek professional advice to navigate these regulations effectively.