VerpackG
Information about the Packaging Act
The Packaging Act (VerpackG) serves to regulate the placing of packaging on the market as well as the return and recycling of packaging waste. It implements two EU directives, the Single-Use Plastics Directive and the Waste Framework Directive, into German law. The Packaging Act only applies in Germany.
The Packaging Act regulates all packaging on the German market. Depending on the different uses, packaging is divided into different types, which mainly include sales packaging, secondary packaging, service packaging, product packaging and transportation packaging. Usually the product packaging stacked at the end consumer belongs to the B2C packaging and the producer has to join the binary system. Transportation packaging that piles up at the end consumer (business), on the other hand, is B2B packaging. Producers are not required to join the dual system, but are allowed to look for recyclers to deal with the B2B packaging directly.
Who is obliged to register for the packaging law?
Producer, retailers and importers, as the primary role in bringing products to Germany for B2C packaging, must join the dual system and register with the Stiftung Zentrale Stelle Verpackungsregister (ZSVR) in order to ensure that their packaging can be recovered and recycled nationwide. From July 2022, the registration obligation will apply to all packaging manufacturers of filled goods. Producer without a branch in Germany can appoint a local authorized representative in Germany.
Primary distributors and secondary distributors (retailers) of packaging for B2B transportation must take back similar packaging waste free of charge and recycle it appropriately. This now also applies to reusable packaging. This means that the final consumer must be informed that the transport packaging can be disposed of for free by the distributor of the B2B Primary distributors and secondary distributors (retailers). To this effect, producers of B2B transport packaging are also obliged to provide relevant recycling plans and documentation.
Which obligations?
Packaging producer and importers must register with the ZSVR Foundation before they can place products with packaging or packaging on the German market for the first time. In addition, they must (as appropriate) join a dual system and pay a recycling fee for the volume they put on the market, which collects and recycles the packaging nationwide. The amount of packaging placed on the German market for the first time must be declared regularly to the packaging register or otherwise face the risk of fines and sales bans.
Violation
Producer, importers and retailers who violate the Packaging Act run the risk of various penalties and other sanctions. Under administrative law, there is a risk of fines of up to EUR 200.000 and other sanctions such as the absorption of profits made. Under private law, there is a risk of warnings from competitors and high claims for damages. In general, there is also the threat of a distribution ban.
Our service
With ECOPV-EU, you receive our exclusive service for compliance with the legal requirements of the Packaging Act. This includes support with the mandatory registration with the Central Agency Packaging Register (ZSVR) as well as the licensing of your packaging with one of the dual systems. We will handle the transmission of your reports for you. All we need are your quantities and your trust.
Specific requirements for manufacturers according to VerpackG
System participation
Producer must participate in a dual system or submit a declaration of completeness.
Licensing In A Dual System
The producer (the first to place a product with packaging on the German market) pays a recycling fee for its packaging in return for a licence and finances the recycling of the packaging.
Quantity reports
Monthly, quarterly or annual reporting of packaging quantities placed on the market to the dual system.
Recyclability
Packaging must meet minimum requirements for recyclability.
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FAQs
Where do I have to register?
In addition to participating in a dual system, companies must also be registered with the Central Agency Packaging Register (ZSVR). This acts as a supervisory authority for compliance with legal obligations.
What is a LUCID number?
The LUCID number is the registration number at the Central Agency Packaging Register (ZSVR). In Germany, all distributors of packaging are obliged to register with the ZSVR. In addition, marketplaces such as Amazon or Ebay must request the LUCID numbers of their retailers.
When do I have to license my packaging?
In principle, all sales packaging that accumulates as waste with the end consumer, i.e. B2C packaging filled with goods, must be licensed. This also includes shipping material and packaging from the food service industry. Packaging from the food service industry is classed as service packaging.
Who is the distributor of packaging?
A producer with a registration obligation is a party that provides packaging containing goods to a third party/end customer for the first time, with or without charge, for the purpose of sale, consumption or use. And these packages usually accumulate as waste at the end consumer.
Who is affected by the Packaging regulations?
The obligation to register affects all packaging producer, regardless of the type of packaging they are filling for retailers in Germany for the first time. Electronic marketplaces and fulfillment service providers take on new responsibilities.
Which packaging is subject to registration?
Whether plastic film, cardboard boxes or glass bottles: all packaging that typically accumulates with the private end consumer and is therefore considered sales packaging must be licensed in accordance with the German Packaging Act (VerpackG).