New Packaging Act (VerpackG) creates more transparency in Germany

The new Packaging Act (VerpackG) has been in force in Germany since 1 January 2019. Germany wants to create more transparency and increase recycling quotas in the area of packaging materials. Who is affected by the law and which body is responsible?

Robot closes packaging

The new Packaging Act (VerpackG) is aimed at encouraging product manufacturers to take more responsibility and generally make a bigger contribution to the reuse, recycling or avoidance of packaging materials. For this purpose, the Central Agency Packaging Register (Zentrale Stelle Verpackungsregister, ZSVR) was created, which has been tasked with the legal implementation of the Packaging Act. The Central Agency Packaging Register takes care of the following tasks: registration of those responsible for products on request, receipt of data reports on packaging quantities, publication of data in a public register, monitoring of registered manufacturers, calculation of market share and verification of (dual systems’) volume flow records, definition of a minimum standard for measuring the recyclability of packaging, etc.

Who is affected by the Packaging Act and who must register?

The new Packaging Act applies to all commercial Swiss exporters who supply packaged goods to private consumers or equivalent bodies (such as gastronomy, hotels or administration) in Germany for the first time. It is important to note that this not only refers to manufacturers, but above all to the initial distributors who supply products and their packaging to Germany for the first time – these can also be dealers and/or importers. Registration with the Central Agency Packaging Register is free of charge for manufacturers. Within the registration process, affected companies are told that they must also fulfill their obligation to participate in one or more dual systems in Germany. This is the only way to fully complete registration.

What counts as packaging and must be registered?

To register in the LUCID Packaging Register, obligated companies must register with their master data and the trademarks they are placing on the market. Companies are obliged when they use any packaging that typically ends up in a private consumer’s trash after use. In addition to classic packaging such as closures, labels and air cushions, this includes all sales, outer and service packaging as well as shipping packaging with filling materials. The Act does not apply to reusable packaging that is subject to a deposit.

If you are unsure whether you need to register your company with the Central Agency in the LUCID Packaging Register, you should first check whether you are placing packaging on the market that is subject to participation in the system. This information can be found in the System Participation Obligation catalog – an overview of various product groups with case studies. Should you have any further questions in this regard, there is also the possibility to clarify a packaging’s system participation obligation by submitting an application to the National Authority.

What information do I need to register?

The following registration and master data is required in order to be included in the Central Agency Packaging Register’s database:

  • Manufacturer's name and address
  • European or national tax number (UST-ID, if available, otherwise tax number)
  • The trademark under which the packaging is marketed (under the Packaging Act, the ZSVR must publish this information)
  • Manufacturer’s contact details (telephone, fax, email address) – (under the Packaging Act, the ZSVR must publish this information)
  • Indication of a responsible person/supplementary processor if applicable
  • National identification number (commercial register number if available, alternatively trade license number)
  • Declaration regarding system participation or on participation in a so-called branch solution
  • Declaration that the request was not made by an authorized third party
  • Declaration that the information provided is true and correct

The Central Agency Packaging Register is obliged to publish the trademark, contact details, registration number and date in the database.

Do you have any further questions about the Packaging Act?

The qualified specialists at ExportHelp will be happy to assist you with specific clarifications and other administrative export issues.



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