The German Packaging Law (VerpackG) is a law aimed at reducing the environmental impact of waste and pollution from packaging.
The VerpackG applies to all companies and online sellers who send packaged shipments to Germany. This law requires sellers to pay a fee to cover the possible costs of recycling and disposal of packaging imported into the country.
The German Packaging Law VerpackG incorporates the European Packaging Directive 94/62/CE into German law.
What should you take into account?
Starting July 1, 2022, marketplaces will have to verify that all sellers shipping packaged goods to Germany are registered with LUCID (Zentrale Stelle Verpackungsregister) and comply with the new Packaging Law.
Who is required to register?
The obligation of the correct management of the containers corresponds to whoever puts the packaged products into circulation for the first time in Germany and whose destination is the final consumer, whether it is a domestic consumer or an industrial/commercial one.
What are your obligations?
- Obligation to register in LUCID the “Zentrale Stelle Verpackungsregister” for all types of packaging.
- Presentation of periodic declarations both to this Central Registry and to a dual system of collection and treatment of containers.
- Adherence to an integrated Management System for Packaging Waste and Used Packaging (GIS). It is mandatory to collect and manage containers of all kinds, regardless of the obligations of registration in the Central Registry. There are different SIGs specialized in each type of packaging and you can participate in several SIGs.
- Failure to comply with the law entails a ban on selling in Germany and is subject to heavy penalties that can reach €200,000.
Several cases can occur:
- Direct sales (online, catalog, etc.): The responsibility lies with the foreign manufacturer or wholesaler who sells their products in Germany.
- Sale through a distributor/importer: The responsibility lies with the owner of the goods upon entry into the German territory. Depending on the agreed Incoterm (rules which define the responsibilities of sellers and buyers), the foreign exporter or the German importer will be responsible.
- Private brands: The owner of the brand that appears on the package is required, except if the manufacturer’s name also appears on the package.
Where should interested companies register?
There is an obligation to register in the Central Packaging Register (Zentrale Stelle Verpackungsregister). The website is also available in English.
The periodic declarations must be presented both to this Central Registry and to a dual system of collection and treatment of containers. This procedure offers greater control and full transparency of the packaging that is put into circulation in Germany. The data will be crossed, since the dual systems are also obliged to declare to the Central Registry the quantities of containers they manage. The list of registered companies is published and can be consulted online.
The license for the use of the trademark “Der grüne Punkt”
- Not mandatory since 2009
- In the case of marking the containers with the logo, a contract for the use of the brand is necessary.
- Brand owner: Duales System Deutschland GmbH (DSD)
The German Packaging Law (VerpackG) is a law aimed at reducing the environmental impact of waste and pollution from packaging.
