Germany's Packaging Act (VerpackG), a core component of the Extended Producer Responsibility (EPR) regulations, mandates that all businesses selling packaged products in Germany must assume responsibility for the recycling and disposal of packaging waste. The principle is straightforward: "producers pay."
Who Must Register Under VerpackG?
The law applies broadly to:
- Manufacturers & brand owners: Any entity whose branding appears on product packaging sold directly to Germany
- Importers: Businesses importing goods into Germany from abroad
- E-commerce sellers: Including marketplace sellers (Amazon, eBay, etc.) and independent store operators
- Cross-border traders: Even without German legal entities, sellers shipping directly to German consumers must comply
Exemptions: Business-to-business (B2B) transactions with proper recycling documentation and special packaging containing hazardous substances follow separate regulations.
Three-Step Compliance Process
1. Obtain LUCID Registration: Register through Germany's Central Packaging Registry (LUCID) to receive a unique identification number.
2. Submit LUCID to Marketplaces: Major e-commerce platforms require verification of this registration number.
3. Contract with Recycling Providers: Partner with authorized waste management companies to purchase recycling quotas based on projected packaging volumes. Annual reporting of actual usage is mandatory.
Non-Compliance Consequences
Failure to adhere carries significant risks:
- Substantial financial penalties from German authorities
- Product delisting or account suspension on marketplaces
- Potential competitor-initiated legal complaints
The VAT-Packaging Law Connection
A German VAT identification number serves as prerequisite for VerpackG registration. The tax identifier enables regulatory agencies to cross-reference compliance data between environmental and fiscal records.