Foreign Businesses Must Navigate Germany’s Strict Packaging Laws

Foreign companies looking to sell packaged products in Germany must adhere to stringent legal requirements set out by the country’s packaging law, known as the VerpackG. These obligations apply regardless of whether the company has a physical presence in Germany, as long as their products reach German consumers.

The law mandates registration, participation in a dual system, and ongoing reporting, all overseen by the Zentrale Stelle Verpackungsregister (ZSVR) through the public LUCID Packaging Register.

Registration Requirements for Foreign Sellers

Any entity introducing packaged goods into the German market for the first time must register with the LUCID Packaging Register before delivering products. The term “producer” encompasses a broad range of entities, including manufacturers, importers, brand owners, and online retailers. Since 2022, this registration requirement applies to all types of packaging, including retail, shipment, industrial, and reusable formats.

Upon successful registration, companies receive a unique LUCID number, which becomes publicly visible. Operating without this valid registration can result in severe penalties and possible sales bans, making compliance essential for foreign businesses.

Participation in Dual Systems

Foreign sellers must also assess whether their packaging requires participation in a licensed dual system. If the packaging is likely to end up in household waste, it must be licensed through an approved dual system. This requirement includes retail packaging, grouped packaging, and shipment packaging utilized in e-commerce deliveries.

To fulfill this requirement, businesses must enter into a system participation agreement with a dual-system operator and pay fees based on the type and volume of packaging they place on the market. These fees are critical as they fund nationwide collection and recycling services.

Companies selling through online marketplaces or fulfillment providers should note that these platforms are now mandated to verify compliance with German packaging laws.

Ongoing Reporting Obligations

Once registered and licensed, companies are required to report their packaging volumes. This data must be submitted to both the selected dual system and LUCID, ensuring that the figures are consistent across both submissions. The frequency of reporting depends on the contract with the system operator, and businesses can adjust projected volumes throughout the year if necessary.

Additionally, larger companies may need to file a declaration of completeness, which is an audited statement detailing all packaging distributed in the preceding calendar year to demonstrate full compliance.

Foreign sellers entering the German market must view the VerpackG as a mandatory framework. The law promotes producer responsibility and aims to ensure that companies contributing to packaging waste also assist in its recovery. Non-compliance is visible in the LUCID system and carries financial and reputational risks, underscoring the importance of early registration and accurate reporting for any international business operating in Germany.

The information provided here is derived from a report originally published by Packaging Gateway, a brand owned by GlobalData. While the information has been included in good faith for general informational purposes, it is not intended as professional advice. Businesses are encouraged to seek specialized guidance before making decisions based on this content.