The German government has enforced new versions of the German Packaging Act (VerpackungsG) and set up a mandatory compliance system that operates as follows:
Each platform (Amazon, Ebay, Zalando, etc) is required to provide for, or contribute to, the prevention and management of waste. To comply with this provision, the Online Market must be able to prove that its partners (Seller) who sell in the German market have each been registered with respective recycling schemes regarding packaging, Waste.
Sellers are responsible for registering with the relevant bodies as well as the appropriate recycling schemes and ensuring that you are compliant to be able to continue selling in Germany.
Extended Producer Responsibility (EPR) is a concept where manufacturers, importers or distributors of products (such as Zalando, Amazon, Ebay and its partners) will bear a significant degree of responsibility for the environmental impacts of their products throughout the product life-cycle.
In order to ensure that their products are part of a recycling program, sellers, therefore, register with a PRO/Recycling System, report the number of products sold, and pay the respective fee to the PRO/Recycling System.
What steps do I need to take?
Any party who is responsible for primary or secondary packaging being in the German market (producer / initial distributor) must register with the Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR) in the LUCID Packaging Register. Once you have registered, you will receive an EPR registration number for your packaging by email.
Please note: The registration number starts with “DE” followed by thirteen digits, for example: DE1234567891011.
You need to obtain a Packaging License to comply with the law. Partners can only license their packaging with a German “dual system” (authorized recycling system). For that, please provide your LUCID registration number to your authorized recycling dual system to enter into a system participation agreement.
Who is considered a Producer?
A producer refers to “any natural or legal person who develops, manufactures, handles, processes sells or imports waste-generating products or the elements and materials used to manufacture them”. Please note that a producer is not the equivalent of a manufacturer.
If a retailer works with an upstream supplier who is considered a producer in Germany (e.g. an importer or a manufacturer), the retailer is not considered a producer.
For packaging, you are accountable for your primary packaging and/or the secondary packaging added by you, such as delivery packaging, i.e. if you place an article within the packaging, you are therefore also considered a producer.
All packaging types (primary and secondary) must be registered in LUCID