VerpackG: Three-stage implementation of first amended version introduced new provisions

Registration requirement for all packaging types
Regardless of what type of packaging you use to distribute your goods commercially for the first time in Germany, you have to be registered with the LUCID Packaging Register.

Registration requirement for service packaging
Final distributors of service packaging are also subject to obligations under German packaging law. Service packaging is packaging that is filled on site and used to enable or support handing over goods to customers. It typically accumulates as waste with private final consumers. Whoever uses this type of packaging to hand over goods to a final consumer  is also required to pay for its recycling. This is called 'system participation'.
For service packaging (packaging subject to system participation), there are two ways to meet the statutory obligations that come with it: you can either purchase pre-participated unfilled packaging or you must fulfil all obligations yourself. In any case, you have to be registered with the LUCID Packaging Register. Further information can be found in our knowledge base on service packaging.

New obligations for marketplaces and fulfilment providers
Since 1 July 2022, electronic marketplaces must check whether online retailers offering products for sale in Germany on their platforms are complying with their obligations under German packaging law. If the online retailer is not registered with the LUCID Packaging Register and has not concluded a system participation agreement, the marketplace must ban the goods from distribution on their platform.

The same applies to fulfilment service providers: they may only perform their services for companies that have fulfilled  their obligation to register with the LUCID Packaging Register and met their system participation requirement.

Some types of single-use beverage packaging previously subject to system participation have been subject to deposit since 1 January 2022. Further information can be found in our deposit obligation knowledge base.

International parties under obligation without a branch within Germany can appoint an authorised representative
International companies without a branch in Germany can appoint an authorised representative located in Germany to fulfil their obligations under packaging law for them. Further information can be found in our authorisation knowledge base.

Since July 2021, the following changes apply regarding the information that must be provided when registering with the LUCID Packaging Register:

• The fax number no longer has to be indicated in the master data for the registered companies and has been deleted from the public register.

• In addition to the previous registration information, companies have to state their European or national taxpayer reference number, which is also published in the public register.

• The e-mail addresses of registered companies are no longer displayed in the public register.

• The LUCID Packaging Register includes additional information about international parties under obligation that have appointed an authorised representative. All register entries are published, including name, address, contact details and the European or national taxpayer reference number of the authorised representative.