Statutory amendments enter into force, fostering transparency and fairness


No one can shirk from their responsibilities any longer: on 1 July 2022, amendments to the Verpackungsgesetz (Packaging Act) entered into force that include various changes for initial distributors of packaging. These amendments mark a giant step towards more transparency and fairness in the packaging recycling market.

The amended version of the Verpackungsgesetz finally entered into force on 1 July. The amendments are the legislator's response to various irreversible developments witnessed in the past years, in particular the massive growth in online retail and takeaway consumption during the coronavirus pandemic. To achieve the waste hierarchy goals, the packaging recycling market needs more transparency, fairness and a level playing field in a first step. The new regulations mark a breakthrough on this path.

No more exceptions: everyone has to register
Every company that is the first to place packaged goods on the Germany market has to register with the LUCID Packaging Register, indicating the corresponding packaging types. The registration requirement now also applies to reusable packaging, transport packaging and single-use beverage packaging subject to deposit. So far, only those companies that filled packaging subject to system participation with goods or imported this packaging into Germany (in particular retail, grouped and shipment packaging) had to register. Whoever places this packaging on the German market is also required to comply with the system participation requirement and file data reports for their packaging volume.

Further information about the new registration requirements can be found in our 'Extended registration requirement' knowledge base. 

Under scrutiny: enhanced checks on online retailers
The pressure on online retailers to fulfil their packaging law obligations has increased with a new legal obligation for electronic marketplaces, which now have to check whether the retailers active on their platforms are registered in the LUCID Packaging Register and are fulfilling the system participation requirement. If online retailers cannot provide evidence of compliance, the marketplaces must no longer enable them to offer their goods. The same applies to fulfilment service providers: they may only do work for parties that are fulfilling their producer responsibility. 

Do you want to know more about the obligations applicable to online retail? Check our 'Mail order companies and online retailers' knowledge base.

Pizza boxes, flower wrap and take-away cups: registration is required for every service packaging
Amendments also apply to companies filling service packaging with goods and handing them over to customers. Service packaging is packaging that is not filled with goods until it reaches the point of sale so that these goods can be handed over to customers. Examples include pizza boxes, cream jars filled at pharmacies, pastry carries at a baker, counter wrap at the butcher, as well as flower wrap and takeaway cups. Companies and retailers purchasing only service packaging with pre-participation from suppliers or wholesalers have had to register since 1 July 2022, even though they have already paid for their packaging's recycling with their pre-participated purchase.

What special provisions apply to service packaging? How can the food and beverage industry fulfil their obligations? And what about other sectors? Our 'Service packaging' knowledge base has the answers to these and other questions.

The Verpackungsgesetz as a driver: Germany sets new international standards
Registration numbers from around the world have skyrocketed in the LUCID Packaging Register, demonstrating that the new regulations are effective in levelling the playing field. "It has been shown once more that Germany has been setting international standards with the Verpackungsgesetz and LUCID, the online packaging register, laying the groundwork for producer responsibility 2.0," said Gunda Rachut, Chair of the Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR). 

Levelling the playing field: click here for an overview of all changes brought about by the amendments to the Verpackungsgesetz.