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Packaging Act (VerpackG)
Manufacturers, dealers or importers who want to bring various types of packaging onto the German market are subject to the German Packaging Act (VerpackG), based on EU Directive 94/62 / EC. We support you in selling your packaging material in accordance with the law in Germany.
Packaging should be returned to the material cycle by taking it back and disposing of it in an environmentally friendly manner or by recycling and recovering usable raw materials. The aim is to avoid waste in order to conserve resources and to recycle it to protect the environment.
Different national laws with country-specific requirements apply across Europe. In Germany, the German Packaging Act (VerpackG) applies to the distribution and proper disposal of packaging material.
Information for domestic and foreign manufacturers, dealers and importers.
General information on the Packaging Act (VerpackG)
Manufacturers, dealers or importers who want to bring packaging and packaging material to the German market are subject to the German Packaging Act (VerpackG), based on EU Directive 94/62 / EC on packaging and packaging waste.
What do the terms VerpackG mean?
The term VerpackG is an abbreviation of the designation of the Packaging Act – Law on the placing on the market, the return and the high-quality recycling of packaging. Different national laws apply in other EU member states.
Who do the registration obligations affect?
Manufacturers, distributors or importers of reusable packaging and packaging material must register with the Central Packaging Register before sales begin and contribute to the disposal costs incurred.
Which products fall under the Packaging Act?
Recyclable packaging and packaging material are affected. The Packaging Act lays down requirements for product stewardship. It is intended to regulate the behavior of the obligated parties in such a way that packaging waste is avoided and sent for reuse or recycling.
What is product stewardship?
Product responsibility of the person placing the product on the market means taking responsibility for a product over its entire service life, from manufacture and sale to free return as well as professional disposal or recycling.
What penalties or fines are possible?
According to Section 9 of the Packaging Act, offenses such as selling without registration or missing a quantity report as administrative offenses are subject to fines of up to a maximum of 100,000 euros per individual case. In addition, sales of the products concerned must be stopped immediately.
Further information on the penalties and fines for violations of the Packaging Act can be found in the following link.
What are the duties?
Manufacturers, distributors or importers must register with the Central Packaging Register before sales begin and contribute to the disposal costs. One of the obligations is the licensing obligation in a dual system, the so-called system participation obligation.
Important: Since 2019, companies must register with the Central Office for Packaging Register / LUCID. This can only be done in person, outsourcing to an authorized representative based in Germany is not possible. Registration takes place online.
What does Amazon need about registration?
Amazon is legally obliged to check these registrations and thus conformity. All three areas of the law – packaging, electrical devices and batteries – are equally affected. The products cannot be sold again without specifying the relevant numbers.
Further information regarding Amazon and the packaging law can be found at the following link.
How long does the registration process take?
The registration as well as the regular quantity reports must be done personally in order to rule out future misuse. However, all other tasks may be carried out by authorized third parties.
The application itself can be carried out within approx. 10-20 minutes. The registration number is issued immediately afterwards and is immediately valid. This means that the registration procedure does not sometimes require several weeks, as is the case with ElektroG / BattG (Stiftung EAR).
Authorization for foreign manufacturers and dealers as part of the registration
Foreign manufacturers without a registered office or branch in Germany must name an authorized representative based in this country. The latter can represent the manufacturer vis-à-vis the joint agency but is also liable for all statutory obligations of the manufacturer.
We would be happy to support you in fulfilling your registration and reporting obligations with the Stiftung Zentrale Stelle Verpackungsregister / LUCID in order to be able to sell your packaging in accordance with the law.
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We are recognized and certified by the Altgeräte Register EAR foundation as a representative for foreign manufacturers, dealers and importers. Our interested parties and clients are internationally active, well-known companies from all parts of the world.
Questions and answers (Q&A)
Frequently asked questions from prospects and customers as well as the corresponding answers.
Registration under the Packaging Act is necessary as soon as packaging is placed on the market for the first time, i.e. when products are placed on the market for the first time.
Licensing is understood to mean the participation of packaging and packaging material in a return system for used packaging (“dual system”).
Licensing is required for every distributor of sales packaging who later sends products to “private end customers”, regardless of the quantity and weight of the packaging.
In principle, packaging tape must also be licensed, as it falls under the “plastics” category. However, there is a regulation that if the packaging has a material content of 5% or less, the packaging tape is considered to be the main material content (e.g. cardboard packaging with <5% foreign content).
In principle, the cardboard box used must be licensed. Since it is difficult or often impossible to provide conclusive evidence of documents for packaging that has already been licensed (for proof of license or a declaration of completeness), licensing should be carried out for your own safety.
In principle, this includes all recyclable materials for packaging, such as glass packaging, paper, cardboard, cardboard or packaging made of tinplate, aluminum, plastic or composite materials.
The easiest way to do this is to use your merchandise management system with a corresponding note for customers or products or based on plausible average values.
You can also weigh and extrapolate the packaging. It is important that the values you provide are conclusive and, in the event of a test, also understandable.
It is not necessary to invoice the entire amount of packaging material used, down to the last gram, the calculated amount should at least correspond to the facts.