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Shipping to Germany: Everything you need to know about the German Packaging Act 

Phil Forbes
Phil Forbes | 5 min read

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Sustainability and the climate are occupying more and more space in public discourse.

The constantly growing flood of packaging waste nonetheless is emerging as a pressing issue around the globe.

The online shopping boom - which generates huge quantities of paper packaging that accounts for a significant proportion of household waste - is one of the major factors behind this trend.

Germany enacted the Packaging Act (VerpackG) on 1 January 2019 in an effort to bring about a significant increase in recycling rates for waste packaging materials.

packaging waste that could be recycled

The Act affects all manufacturers and retailers that sell packaged goods to consumers in Germany – so it applies to companies shipping internationally, too.

This article takes a closer look at what you need to know if you ship goods to or within Germany.

What does the German Packaging Act actually involve?

The Act affects not only German companies but, in fact, all international retailers and manufacturers that ship goods to end-users in Germany.

Any company that sends goods placed in sales packaging for the first time (product packaging, mail-order packaging and service packaging) to German private customers has to contribute to the costs of collecting, sorting and recycling the packaging waste that is created by paying a ‘licence fee’. 

The licence fee amount is based on the volume and materials contained in packaging placed on the market.

The fee is paid to one of the ‘dual systems’ – accredited private companies that ensure that packaging waste goes through waste management and recycling processes.

By taking this step, companies placing goods on the market take responsibility for their packaging and help to create an efficient resource loop. 

The German Packaging Act’s primary goal is to achieve significant increases in recycling rates for packaging waste - and take the notion of the circular economy to a whole new level.

Click here to see Packhelp's range of recyclable packaging solutions

Who is affected?

Any company that places goods in sales packaging for the first time, imports them into Germany and sends them to German end-users or sells them within Germany is considered the ‘initial distributor’ and has to comply with the VerpackG’s obligations.

This applies to every single company – regardless of its size - and notably includes licensing (or participation) in a dual system. 

Foreign companies can, therefore, be directly affected by this legislation as well – at the exact point when they ship goods, including their packaging, directly to German consumers without using an intermediary.

It should be noted that all packaging must be licensed – both product packaging and shipping packaging including filling and padding materials.

Important to note: International retailers should clear up who is responsible for goods when they cross the border beforehand.

That company must then fulfil all legal obligations arising from the VerpackG.

Normally, the importer is responsible, although the contractual parties involved should unambiguously set out who the responsible party is in a contract. 

What kinds of packaging need to be licensed?

All kinds of packaging that ultimately end up with and have to be disposed of by German end-users must be licensed.

In other words: ‘sales packaging’, which includes product packaging, mail-order packaging (including filing and padding materials) and service packaging. 

coco and eve unboxing

The VerpackG’s obligations apply from the very first piece of packaging placed on the market.

Moreover, each material must be licensed, regardless of whether it is made of cardboard, plastic or glass.

What exactly do I need to do?

Under the VerpackG, each company placing sales packaging on the market for the first time is required to meet the three following obligations – before the first piece of packaging is sold:

  1. Registration: The company must register in full with the Central Agency Packaging Register (ZSVR) through the LUCID Packaging Register. Once registered, the company is listed in the publicly accessible LUCID database.
  2. System participation: The packaging that a first distributor places on the German market must be licensed with a dual system (e.g. with Interseroh through the Lizenzero online shop) by paying a ‘licence fee’. The company makes a contribution towards the proper take-back, sorting and recycling of its packaging by paying this fee. The dual system must be notified of the registration number that you were emailed after completing the registration process described in point 1 so that the ZSVR can check that your company is meeting its obligations. 
  3. Data reporting: Finally, the volume of licensed packaging and the name of the dual system must be entered into LUCID. Companies have an ongoing duty when reporting data to make sure that any changes, for instance relating to the volume licensed with the dual system, are always be registered identically in LUCID. In particular, the reported volumes must always match in order to ensure proper compliance with the obligation.

What happens if a company violates the VerpackG?

A company subject to the licensing obligations may face severe penalties if it does not comply fully or properly with its obligations.

These penalties can range from written warnings to fines of up to €200,000 or even sales bans. 

The Central Agency Packaging Register was already actively imposing penalties in summer 2019.

It handed over roughly 2,000 cases of non-compliance to the responsible enforcement bodies and sent out a mass email warning tens of thousands of affected companies.

The authority also announced that it would take wide-ranging actions in 2020 since a significant number of companies are still not living up to their obligations.

The bottom line: take action now

The German Packaging Act was created to raise recycling rates for the growing flood of packaging waste and to motivate companies to be more sustainable as they take responsibility for their products.

wedding boxes by Onka

All companies sending packaging to German consumers are affected by the VerpackG, including companies that export goods to Germany.

Complying with the obligations is absolutely essential – or you run the risk of facing stiff penalties.

Companies like Lizenzero can help

As an affected company, you can license your packaging quickly and easily in just a few steps with the help of our partner Lizenzero - the online shop for packaging licensing operated by Interseroh’s dual system – and take care of this process completely online.

Take advantage of an exclusive 10% discount for licensing your packaging now in cooperation with Packhelp and make sure that you are on the right side of the law!

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