Legal amendments effective 1 July 2022
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Amendments to the Verpackungsgesetz (Packaging Act) will bring about new obligations that must be complied with starting 1 July 2022. From that day onwards, companies have to have registered with the LUCID Packaging Register, no matter what type of packaging they place on the German market with their goods, and additional new obligations will apply to electronic marketplaces and fulfilment services providers.
Every company that places packaged goods on the German market on a commercial basis must have registered with the LUCID Packaging Register by 1 July 2022. The obligation applies to all types of packaging, be it retail, grouped and shipment packaging, transport packaging, reusable packaging, industrial packaging or single-use beverage packaging subject to deposit, etc.
The obligation also applies to final distributors of service packaging that have delegated all of their duties to an upstream distributor; they, too, must register. Breaches will result in a distribution ban. To ensure that all companies affected can comply with their obligations in good time, the new registration process will start on 5 May 2022.
Electronic marketplaces are required to verify whether retailers and sellers of goods are registered in the LUCID Packaging Register and whether they comply with the system participation requirement. Only if they are registered and comply with the system participation requirement are electronic marketplaces allowed to offer their goods. The same applies to fulfilment service providers: they, too, must ensure that the ordering party complies with all statutory obligations. Otherwise, fulfilment service providers are no longer allowed to offer their services to their ordering parties. To make it easier for electronic marketplaces and fulfilment services providers to comply with their new obligations, the ZSVR will offer them and other interested parties the option to consult the register and retrieve a register excerpt XML file every day starting June 2022.