Packaging Act
Companies in Germany must comply with clear rules when it comes to packaging. The Packaging Act (VerpackG) requires producers, retailers and importers to take responsibility for the entire life cycle of their packaging – from use to recycling.
Key information
- Since 1 July 2022, registration has been mandatory for all types of packaging – including transport and reusable packaging, which was not previously affected.
- Germany’s central packaging registration authority (ZSVR) monitors compliance and maintains the public register “LUCID”.
- The intention of stricter reporting and documentation requirements is to make data more transparent and force “free riders” out of the market.
Wichtige Infos
- Seit dem 1. Juli 2022 gilt die allgemeine Registrierungspflicht für alle Verpackungsarten – das betrifft auch Transport- und Mehrwegverpackungen, die bisher nicht erfasst waren.
- Die Zentrale Stelle Verpackungsregister (ZSVR) überwacht die Einhaltung und führt das öffentliche Register „LUCID“.
- Durch strengere Melde- und Nachweispflichten sollen Daten transparenter werden und „Trittbrettfahrer“ aus dem Markt gedrängt werden.
Goals of the legislation
The German Packaging Act (VerpackG) replaces the country’s earlier Packaging Ordinance (VerpackV). The Act creates the legal framework for environmentally responsible practices in relation to packaging and regulates who is responsible for collection, take-back and recycling. It also transposes key EU requirements into national law, including extended producer responsibility (EPR).
A company’s responsibility does not end when it sells its product. It must also ensure that its packaging is collected, sorted and recycled – and bear the associated costs.
A company’s responsibility does not end when it sells its product. It must also ensure that its packaging is collected, sorted and recycled – and bear the associated costs.
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Prevent packaging waste
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Improve packaging recyclability
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Strengthen the circular economy in Germany
Who is affected and what are the obligations?
The Packaging Act applies to all companies that place filled packaging on the market in Germany for the first time – i.e. producers, retailers, importers and online traders. This covers sales packaging, including shipping and service packaging, grouped packaging and transport packaging as well as reusable and single-use beverage packaging. Sales and shipping packaging must participate in Germany’s dual waste collection system (“the dual system”), while transport and reusable packaging are subject to separate take-back and documentation obligations.
Registration with Germany’s central packaging registration authority (ZSVR) via the “LUCID” register
Obligation to participate in a dual system for all packaging that’s subject to system participation
Volume reporting in LUCID and the dual system (first time, during the year, final)
Obligations to provide evidence and documentation (for certain types of packaging subject to verification)
Which packaging is affected?
Sales
packaging
Includes all packaging that accumulates as waste with end consumers – in-store or by mail order.
Grouped packaging
Used in addition to sales packaging to bundle
products or improve their presentation.
products or improve their presentation.
Transport packaging
Protects goods as they move along the supply chain and facilitates handling and logistics processes.
Reusable and single-use beverage packaging
Refers to all packaging for beverages that is either reused multiple times or disposed of after a single use, as the case may be.
Penalties for infringements
Distribution ban
imposed on unregistered packaging
Fines
of up to €200,000
Turn your obligation into a competitive advantage.
The Packaging Act applies to all companies that place packaging on the market. The crucial factor is how it’s implemented: if you merely fulfil your obligations, you’ll remain legally compliant, but you’ll miss out on opportunities. With a forward-looking strategy, you can, for example, reduce the size of your packaging, avoid unnecessary materials like polystyrene and use sustainable alternatives – reducing costs in the long term and strengthening your market position at the same time.
Case study.
An online retailer ships its products in sturdy shipping boxes. Loose polystyrene filling material is used to give the goods extra protection. Although this keeps goods safe during transport, it also leads to higher system participation costs, as the box and
the filling material must be licensed separately.
the filling material must be licensed separately.
Benefits
Optimised packaging design not only cuts costs; it also offers other advantages.
Reduced system participation costs thanks to optimised materials
Improved recyclability and a positive signal to customers
Compliance with legal requirements remains assured
Basis for upcoming EU rules
As well as being a national law in Germany, the Packaging Act is an important step towards implementing future EU rules such as the Packaging and Packaging Waste Regulation (PPWR). Companies that align their packaging processes with this legislation today are also laying the foundations
to fulfil upcoming EU requirements and robust sustainability reporting compliant with the CSRD.
to fulfil upcoming EU requirements and robust sustainability reporting compliant with the CSRD.
PPWR
The aim of the planned Packaging and Packaging Waste Regulation (PPWR) is to standardise packaging requirements across the EU. The goal is to reduce waste, increase recycling rates and promote the use of recycled materials. Companies must therefore engage with the new requirements well in advance so that they can adjust their processes and packaging in good time.
CSRD reporting
The Corporate Sustainability Reporting Directive (CSRD) extends sustainability reporting requirements in the EU. The goals are to establish transparency, increase comparability and embed sustainability more firmly in business practices. Companies must therefore adapt to the new standards in good time so that they can ensure their reports are well-structured and compliant.
We’re here to help you.
We will assist you with all the operational and administrative tasks so that you can fulfil your obligations under the Packaging Act confidently and efficiently.
Registration service
Support with enrolment in the LUCID register.
Compliance monitoring
Regular checks and advice on legal changes and deadlines.
The benefits for you: legal certainty, reduced administrative burden and verified data that can also be used for PPWR and CSRD reporting.
Support you can rely on.
You want to be certain that processes are effective, rules are followed and help is available whenever you need it. Our transparent, reliable and practical services are designed to satisfy all of these needs.
Expertise
We continuously analyse and adapt to the latest requirements and market developments. We help companies understand which requirements are relevant to them now and which will be in the future.
Advice
We take a practical approach to resolving individual issues, developing specific recommended actions that combine legal certainty with cost-effectiveness.
Legal certainty
All processes – from packaging design to volume reporting – are based on current requirements. Companies act in compliance with the rules at all times.
Implementation
From dual-system participation to reporting, in addition to planning measures, we also provide operational support until quantifiable results are achieved.
Efficiency
Complex processes are structured, digitally supported and clearly documented. This reduces internal effort and creates space for core business activities.
Zentek Group
We are happy to advise you
Work with us and we will offer you advice and support. Our team of experienced experts is always available to answer your questions.