Understanding the Verpackungsgesetz : Packaging Licensing for Online Sellers

An Essential Environmental Regulation

With the rapid expansion of e-commerce and the resulting surge in packaging waste, Germany has introduced a strict regulatory framework to ensure companies take responsibility for their environmental impact. Known as the Verpackungsgesetz, or Packaging Act, this law applies to all businesses that introduce packaging into the German market, especially online sellers. Since coming into effect on January 1, 2019, the Verpackungsgesetz has become a vital part of Germany’s circular economy strategy. For sellers, compliance is not a choice—it’s a legal obligation.

The primary goals of this law are to reduce the environmental impact of packaging waste, to increase recycling rates, and to promote the use of eco-friendly, recyclable materials. Any company placing packaged goods onto the German market is required to register, report, and financially contribute to the recycling of the materials it uses.

Who Is Affected?

Contrary to what some might think, the law does not only target large corporations or manufacturers. Every business shipping goods to end consumers in Germany is subject to the Verpackungsgesetz. This includes e-commerce platforms, individual online retailers, self-employed entrepreneurs, and even foreign sellers delivering products directly to German customers.

If you package and ship products to Germany, you are considered the “initial distributor” of that packaging on the German market. It makes no difference how small your operation is—even sending a few parcels per year makes you subject to the law.

What Types of Packaging Are Covered?

The Verpackungsgesetz applies to any type of packaging that is handed over to a private end consumer and ends up in household waste. This includes:

• Shipping and transport packaging, such as boxes, envelopes, tape, and padding.

• Sales packaging, which directly encloses the product (e.g., jars, bottles, boxes, bags).

• Secondary packaging, like plastic wraps or additional layers that group products.

• Service packaging, such as coffee cups or takeaway containers in the food sector.

If the packaging will likely end up in a German household trash bin, it falls under the scope of the law.

Mandatory Registration with the LUCID Packaging Register

The first step toward compliance is registering with LUCID, the public packaging register operated by the Zentrale Stelle Verpackungsregister (ZSVR). This process is free of charge and must be completed before shipping any goods to German consumers.

During registration, you provide your company details and declare the types of packaging you use. Once registered, your business becomes publicly visible in the LUCID database, allowing authorities, customers, and marketplaces to verify that you are legally compliant.

Packaging Licensing Through a Dual System

In addition to registering with LUCID, you must also license your packaging through a dual system. These are authorized waste management companies that collect, sort, and recycle packaging materials on your behalf. Some well-known providers include Der Grüne Punkt, Interseroh, and BellandVision.

You will need to estimate and declare the total weight of each type of material you will introduce into the German market throughout the year—such as paper, plastic, glass, or aluminum—and pay a licensing fee accordingly. The cost is usually modest for small sellers but scales with the volume of packaging used.

Annual Reporting and Further Obligations

At the end of each calendar year—or periodically depending on your contract—you must update your declarations with both your dual system provider and in the LUCID register, reporting the actual quantities of packaging used.

If your packaging volumes exceed certain thresholds (e.g., >50,000 kg of paper/cardboard or >80,000 kg of glass), you are also required to submit a Declaration of Completeness, certified by an independent auditor. While this does not apply to most small sellers, it is important to know about for scaling operations.

Consequences of Non-Compliance

Failure to comply with the Verpackungsgesetz can lead to severe penalties. Businesses that do not register, fail to license their packaging, or underreport their volumes risk fines of up to €200,000 and even sales bans in the German market.

Moreover, major marketplaces such as Amazon, eBay, and Etsy are now legally required to check whether sellers are properly registered and licensed. If you are not compliant, you may find your seller account suspended or deactivated without warning.

Compliance as a Competitive Advantage

Complying with the Verpackungsgesetz is not just a legal duty—it can also be a strategic business advantage. German consumers are particularly eco-conscious, and demonstrating responsible packaging practices builds trust and enhances your brand reputation.

Proper compliance also leads to optimized logistics, helps you cut down on unnecessary packaging, and aligns your operations with growing European regulations on sustainability and waste reduction.

Best Practices to Stay Compliant

To ensure ongoing compliance, it’s important to track your packaging usage throughout the year, opt for recyclable or compostable materials, retain your licensing certificates and invoices, and update your information in LUCID if anything changes. Reducing the size and complexity of your packaging can also lower both your environmental impact and your licensing fees.

Conclusion: Register, License, Recycle

In conclusion, the Verpackungsgesetz requires every online seller shipping products to Germany to register with LUCID, join a dual system, declare packaging volumes, and contribute financially to recycling. While it may seem bureaucratic at first glance, it plays a critical role in reducing waste and promoting sustainable business practices.

By understanding and fulfilling these obligations, you protect your access to one of Europe’s most lucrative markets and position your business as a responsible and forward-thinking player in the e-commerce space. In today’s world, compliance is not just about avoiding penalties—it’s about meeting consumer expectations and contributing to a greener future.