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Your obligations under German packaging law

Regardless of whether you are producing and packaging goods, whether you are shipping them or importing them: if you are acting commercially, you are considered to be the producer under German packaging law. The obligations that you have to fulfil depend on your packaging.

Packaging that is subject to system participation typically accumulates as waste with private final consumers. The sector, distribution channel or individual circumstances do not matter.

Who is a private final consumer?

The Verpackungsgesetz (Packaging Act) defines private final consumers as private households and comparable sources of waste generation such as restaurants, hotels, hospitals, canteens, amusement parks, garden centres, laundries, libraries and schools. This also includes craft enterprises and agricultural holdings where packaging waste is collected at the rate that is normally associated with private households at 14-day intervals and in a waste bin that does not exceed 1,100 litres per collection group. A list of of comparable sources of waste generation can be found here.

What you need to know

You have three obligations to fulfil for packaging subject to system participation (retail, grouped or shipment 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. Regularly report your packaging volumes (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).

Find out more

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).

A level playing field is key if we want to protect our environment. Companies must ensure that their packaging harms the environment as little as possible. This is referred to as assuming 'producer responsibility', which governed by the Verpackungsgesetz (Packaging Act). Where packaging cannot be prevented, all market players that distribute packaged goods must be registered with the LUCID Packaging Register. Another factor is that 'high-quality' recycling of packaging waste is only possible in a financially sound market. That is why you are required to pay for the recycling of your retail, grouped or shipment packaging that is subject to system participation by concluding a 'system participation agreement' with a system operator.