Information & Orientation

Extended producer responsibility for packaging in the context of the Verpackungsgesetz (Packaging Act)

In Europe, packaging is subject to so-called extended producer responsibility. That means that, by placing packaged goods onto the market, the parties that do so also assume responsibility for ensuring that the packaging damages the environment as little as possible.

Of course, if packaging never comes into existence in the first place, this will cause the least amount of damage. That is why the prevention of packaging is at the very top of the hierarchy of goals. The changes that society has undergone in recent years, such as the sharp rise in online retail and takeaways (to-go coffee), an increase in single-person households, and more working parents (more processed foods and ready meals) have led to a marked increase in the use of packaging. The ecological footprint of packaged goods is generally much greater than that of the packaging itself. Against this backdrop, requirements for packaging have also increased. In keeping with the principle of prevention, packaging is designed to increase the shelf life of products considerably. However, it is precisely this issue which currently leads to situations where occasionally packaging is used that is only partly suitable for recycling, or which cannot undergo high-quality recycling, for example because of the use of barrier coatings. Another example is small 'single-serving' packaging, which prevents food waste but increases the use of packaging and leads to an increase in the number of packaging units. These conflicting ecological goals highlight the complexity of the issue.

It is for this reason that it is all the more important that in situations where the use of packaging cannot be prevented, such packaging should be reusable or suitable for high-quality recycling. Producer responsibility must be structured comprehensively; the entire value chain has to be engaged, and consumers need to be provided with more information. In order to make this a reality, it is necessary to set and achieve high quantitative and qualitative targets. This is what the Verpackungsgesetz (Packaging Act) of 12 July 2017 is designed to implement.



Here is a summary of the Verpackungsgesetz (Packaging Act), in bullet points, from the Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR)'s perspective:


System participation

Producers must ensure the recovery of any of its packaging that is subject to system participation. In order to do so, they enter into a contract with a system. That is nothing new. The producer's payment obligation is an early incentive to prevent packaging. Those who place less packaging onto the German market as a matter of course need to devote fewer financial resources to assuming extended producer responsibility for their products. In the past, this has worked well, at least with those who actually fulfilled this obligation; however, there has been a high proportion of free riders – particularly in areas that experienced high increases in the use of packaging.

A systems overview can be found here.


Registration, data reporting and standards administered by the ZSVR

In order to put a stop to free riding, the Verpackungsgesetz clarified a number of definitions and provisions, and created the ZSVR:

  • Parties responsible for products will be registered in the LUCID Packaging Register, so anyone can see who they are.
  • The administrative regulations of the ZSVR provide legally certain definitions of the obligations, which are thus defined equally for everyone.
  • The centralised database enables the ZSVR to transparently check whether all the involved parties have properly reported their volumes.

This will hopefully mean that soon all producers/distributors will benefit from the ecological incentive effect created through participating in the system.

The LUCID Packaging Register can be found here.


Market share calculation by the ZSVR

The systems also have to report their volumes to the ZSVR so that their costs correspond precisely to their participation volumes. This creates an even playing field between the systems; the rules are set by the ZSVR in coordination with the German Federal Cartel Office.

More information about the market share calculation can be found here.


Recycling targets

Recovery target quotas are being raised to a point where it will only be possible to achieve them if all the parties involved make a concerted effort. Measures will be required at every stage of the value chain. The ZSVR will monitor recycling targets to ensure transparency in this respect as well. This is a massive drive for the environmental sector in Germany – new technology that is needed urgently around the globe needs to be developed.

The recycling targets can be found here.


Recycling-friendly packaging design

Every year, the ZSVR develops and publishes a minimum standard to measure how recycling-friendly the design of packaging is. Using this as a basis, systems must then create financial incentives to encourage sustainable design in packaging. Doing so is vital to achieving the high target quotas over the long term, as well as to attaining the goals of the Verpackungsgesetz. It strengthens the ecological incentives created by system participation fees.

More information about recycling-friendly packaging design can be found here.



The systems must provide information about recovery figures and the rationale of separate collection systems, both regionally and transregionally. The quality of recyclable waste collections has deteriorated continuously over the last several years because the pre-sorting efforts of consumers (which are critically important) have not been supported through informational campaigns and motivation. This will have to change if target quotas are to be met.

Click here for the Packaging Act

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