Foreign Businesses Must Comply with New German Packaging Regulations

Foreign businesses aiming to sell packaged goods in Germany must navigate a set of legal obligations established by the country’s stringent packaging laws. These requirements apply even to companies without a physical presence in Germany, provided their products reach German consumers. Compliance is overseen by the Zentrale Stelle Verpackungsregister (ZSVR) and necessitates registration, participation in a dual system, and ongoing reporting.

Registration in the LUCID Packaging Register

Any company introducing packaged products to the German market for the first time must register in the LUCID Packaging Register before shipping goods. Under this law, a “producer” can include manufacturers, importers, brand owners, online retailers, or any entity placing packaging into circulation. Since 2022, this registration requirement encompasses all types of packaging, including retail, shipment, industrial, and reusable formats.

Once registered, a company receives a unique LUCID number, which is publicly accessible. Operating without a valid registration can lead to severe penalties and potential sales bans, emphasizing the importance of compliance for foreign sellers.

Participation in a Dual System

Foreign sellers must also determine if their packaging necessitates participation in a dual system. If the packaging will end up as household waste, it must be licensed through a recognized dual system. This requirement applies to retail, grouped, and shipment packaging, particularly for e-commerce deliveries.

To comply, businesses must sign participation agreements with a dual system operator and pay fees based on the material and volume of their packaging. These fees support nationwide collection and recycling services, ensuring environmental responsibilities are met. Companies selling through online marketplaces or fulfilment providers should note that these platforms are now required to verify compliance with the packaging regulations.

Following registration and licensing, companies must report their packaging volumes. This data must be submitted to both the selected dual system and LUCID, with identical figures required across both submissions. The frequency of reporting is contingent on the contract with the system operator, allowing businesses to adjust expected volumes throughout the year if necessary. Larger companies may also need to submit a declaration of completeness, an audited statement detailing all packaging distributed in the previous calendar year.

Foreign sellers entering the German market must regard the VerpackG as a mandatory framework. The law reinforces producer responsibility, ensuring that companies contributing to packaging waste also participate in its recovery. Non-compliance is publicly documented in the LUCID registry, which can lead to both financial and reputational damage, highlighting the necessity for early registration and precise reporting for any international business operating in Germany.

The information presented here has been adapted from content originally published by Packaging Gateway, a brand under GlobalData. While it aims to inform, it is not intended as professional advice. Businesses are encouraged to seek specialist guidance to navigate these regulations effectively.