- Essential questions for implementing the Verpackungsgesetz (Packaging Act)
- How-to guide
- Overview for retail companies
- Key considerations on imports
- Issues and specific situations for mail order companies and online retailers
- Overview for small and micro distributors
- Delineation between packaging and non-packaging
The Verpackungsgesetz defines the obligations of producers and retailers – the so-called initial distributors of packaging.
The central obligations of the Verpackungsverordnung (Packaging Ordinance), which had been in force previously, remain unchanged: packaging that typically accumulates as waste with private households or with comparable sources of waste generation, and that has been placed onto the German market commercially, must participate in a system. Only in this way can it be ensured that a nationwide system records all packaging and makes sure all packaging is transfered for recovery.
However, there are also new provisions, such as that recycling-friendly design shall be rewarded. Furthermore, there are new requirements in the interests of transparency which are met by the Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR), such as registration of producers and the submission of data reports on system participation.
The ZSVR’s LUCID Packaging Register is where all the threads come together. This is where producers whose packaging is subject to system participation must register.
For further information or specific issues, please also refer to our FAQs, where you will find answers to relevant questions.
Here you can find concise answers to the ten most important questions, including: Who is affected by the Verpackungsgesetz? Who is under obligation and what needs to be done? What is the role of the ZSVR?
This guide provides information about the obligations regarding producer responsibility and the registration process.
The final distributor in Germany must ensure that the requirements of the Verpackungsgesetz are met, otherwise the goods will automatically be banned from distribution in Germany. For further details on this matter, please refer to this paper.
There are many different set-ups for importing goods. This subject-specific paper provides information about the obligations which have to be met when importing packaging subject to system participation into Germany.
Not all mail order companies are the same, some have very different set-ups: drop shipping, the use of fulfilment, combination with imports, etc. The different set-ups and the resulting implications are set out in this document.
Anyone who has registered or has to register their self-employment as a business or anyone who generates income from commercial activities, independent work or agriculture and forestry with a view to making a profit within the meaning of German income tax law is operating commercially in all cases within the meaning of the Verpackungsgesetz. This paper for small and micro distributors provides information about when distribution is considered to be commercial, and includes guidance for agriculture and forestry.
When does an item qualify as packaging, and which criteria must be reviewed when determining its packaging status? In most cases, it is obvious if a certain item is packaging or not. There are, however, individual cases where this question cannot be answered conclusively at first glance. The ZSVR's new subject-specific paper gives guidance on how to delineate packaging from non-packaging. If a test item qualifies as packaging, it must then be determined whether it is subject to system participation. This is where the system participation requirement catalogue can help.