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Packaging law obligations of start-ups and new business founders

Are you new to the market, distributing packaged goods in Germany? If the answer is 'yes', then you are considered to be a producer under German packaging law. That means you have certain obligations to fulfil. The obligations you have to fulfil depend on the packaging type you are distributing.

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Taking care of business – the Packaging Register

German packaging law made easy: this comic strip will help you understand and fulfil your obligations under the Verpackungsgesetz (Packaging Act).

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Even as a small distributor you have packaging law obligations to fulfil. If you are operating commercially, there is no de minimis threshold or exemption for companies with low packaging volumes.

Chart: Packaging categorisation and system participation

What types of packaging are there? What are the statutory obligations that come with each of them?

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What you need to know

You have three obligations to fulfil for packaging subject to system participation (retail, grouped, shipment or service packaging): registration, participation, reporting.

  1. Register with the LUCID Packaging Register.

  2. Enter into a system participation agreement with a system operator. Please refer to this list for an overview of system operators.

  3. You now have to regularly report your packaging volumes to both your system operator and the LUCID Packaging Register (data reporting).

You can use the system participation requirement catalogue to search for the products that you distribute and find out if their specific packaging is subject to system participation. The search results are broken down by material, packaging type and delineation criterion of the respective packaging (quantity for food products, volume or unit for non-food products).

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Registration: For packaging that is not subject to system participation, you are required to register with the LUCID Packaging Register. You are also required to fulfil certain return and recovery obligations and to provide evidence that you have done so. For details, please refer to section 15 VerpackG (Packaging Act).

Are you distributing goods in packaging that is subject to system participation? If you are, then you must fulfil the system participation requirement. You must also regularly report your packaging volumes (data reporting).

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Checklist: Determining relevance

Check whether any obligations under German packaging law apply to your company.

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Checklist: How to fulfil your obligations under German packaging law in three steps

Registration, participation, reporting: Find out how to fulfil your obligations that relate to packaging subject to system participation.

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Are you using service packaging to hand over your goods or are your customers filling service packaging with goods at the point of sale? Then you have obligations under German packaging law to comply with.

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Your obligations at a glance

Registration
[Translate to English:] Führt zur Seite Alle Informationen zur Registrierung.

Every company that distributes packaged good commercially on the German market or imports packaged goods into Germany has to register with the LUCID Packaging Register, regardless of where in the world that company is based.

System participation
[Translate to English:] Führt zur Seite Systembeteiligung

Pay for the recycling of your packaging subject to system participation (retail, grouped or shipment packaging) by concluding a system participation agreement with a system operator.

Data reporting
[Translate to English:] Führt zur Seite Datenmeldung.

Regularly report the volumes of your packaging subject to system participation to your system operator and the LUCID Packaging Register.