Foreign Sellers Must Navigate Strict German Packaging Laws

Foreign companies aiming to sell packaged goods in Germany must adhere to stringent legal obligations outlined by the country’s packaging regulations. These requirements apply regardless of a company’s physical presence in Germany, as long as their products reach German consumers. Key elements of the law include registration, participation in a dual system, and ongoing reporting, all managed by the Zentrale Stelle Verpackungsregister (ZSVR) through the public LUCID Packaging Register.

Registration Requirements for Foreign Businesses

Any foreign business introducing packaged products to the German market is required to register in the LUCID Packaging Register prior to shipping their goods. Under the legislation, a “producer” encompasses manufacturers, importers, brand owners, online retailers, and any entity placing packaging into circulation for the first time. Since the beginning of 2022, the registration duty extends to all types of packaging, including retail, shipment, industrial, and reusable formats. Upon registration, businesses receive a unique LUCID number, which is publicly accessible. Operating without this registration can lead to substantial penalties and potential sales bans.

Compliance with the Dual System

Foreign sellers must ascertain whether their packaging is subject to system participation, particularly if it will end up as private consumer waste. Such packaging must be licensed through a recognized dual system, which covers retail, grouped, 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 based on the material and volume of packaging placed on the market. These fees support nationwide collection and recycling initiatives.

Additionally, businesses utilizing online marketplaces or fulfilment providers should note that these platforms are now obligated to verify compliance with packaging regulations.

Once registered and licensed, companies must also report their packaging volumes. This data must be submitted to both the selected dual system and to LUCID, ensuring consistency across both submissions. The frequency of reporting is contingent on the contract with the system operator, with businesses able to update expected volumes throughout the year. Larger companies may also need to file a declaration of completeness, providing an audited statement of all packaging distributed in the previous calendar year to verify compliance.

The VerpackG serves as a mandatory framework for foreign sellers entering the German market. The law promotes producer responsibility, ensuring that companies contributing to packaging waste also participate in its recovery. Non-compliance is publicly recorded in the LUCID system, posing financial and reputational risks for businesses. As such, timely registration and accurate reporting are crucial for any international entity engaging in trade in Germany.

The information presented here is based on insights from Packaging Gateway, a brand under GlobalData. It is intended for general informational purposes and is not a substitute for professional advice. Companies are encouraged to seek specialized guidance to navigate these regulations effectively.