Licensing, return, recycling & disposal of packaging in accordance with the new German Packaging Act (VerpackG)

Correct disposal of transport, sales and grouped packaging

Put packaging into circulation in a differentiated, legally compliant and cost-effective manner – with Deutsche Recycling! We know what is required in which country.

Kartons, Verpackungen auf einer Palette

Packaging is recyclable material that is collected, sorted and recycled (e.g. cardboard boxes, sales packaging such as yoghurt pots or plastic bags). Within the EU, the handling of packaging and packaging waste is regulated by Directive 94/62/EC. The EU Packaging Waste Directive includes, among other things, what is known as “extended producer responsibility”.

However, similar laws now apply far beyond the EU, for example in Macedonia and Belarus, as well as in Israel, Brazil and Asian countries such as China and Japan. Deutsche Recycling is your number 1 partner when it comes to correctly licensing and registering sales and grouped packaging in accordance with the specific requirements of each country, as well as disposing of this along with transport packaging.

The new German Packaging Act (VerpackG) entered into force on 1st January 2019, thus rendering invalid the Packaging Ordinance, which was in force until 31st December 2018. The aim of the law is to reduce the negative impacts of packaging waste on the environment and to significantly increase recycling rates. As a retailer, you face new challenges, and we will be happy to provide you with information and advice here.

Who is affected by the new German Packaging Act?

There are no exceptions for small-scale entrepreneurs and/or small businesses, as all manufacturers and retailers are affected equally by the provisions of the new German Packaging Act. If you put commercial packaging into circulation or manufacture it, you are obliged to have it returned and dispose of it properly. The regulations therefore even apply to small online retailers who use sales and/or transport packaging to ship the goods sold.

According to the definition of the law, you are considered a manufacturer if you put packaging into circulation commercially for the first time (see Article 3 – Definitions) and this also applies to retailers who import packaging into Germany. If you continue to use packaging commercially for shipping, the legislator regards you as a distributor. A final distributor sends the packaging to the respective end consumer, who does not put the ordered goods into circulation any further. In addition to private households, trade businesses, restaurants, hospitals and similar establishments can also be regarded as end consumers.

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Sales packaging

Whether yoghurt pots, cans, washing-up liquid bottles, disposable crockery, bread rolls or shopping bags: Sales packaging includes any type of packaging that, unlike transport packaging, is directly amassed by the end consumer.

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Transport packaging

In accordance with the VerpackG, all manufacturers and distributors are responsible for the recycling and disposal of the (transport) packaging they put into circulation. The Packaging law also applies to wholesale and online trade.

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International packaging licensing

The European Packaging Waste Directive (94/62/EC) regulates the handling of packaging put into circulation at an EU level. However, the regulations regarding return and recycling differ from country to country.

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Deutsche Recycling offers meaningful and professional solutions for the recycling, disposal and licensing of packaging at a national and international level. We support you in returning and recycling all sales and transport packaging placed on the market, take care of the initial needs analysis and then quantity reports, reporting and invoicing with the appropriate systems for sales packaging. In addition, we optimise your licensing solutions and also act where there are different country-specific requirements.

Definition of the term ‘packaging’

Article 3 of the Act also contains the definition of packaging. The legislator defines the term very broadly because the regulations apply to all packaging. In addition to conventional sales packaging and grouped packaging, this also includes transport packaging for shipping to the customer. However, containers are excluded from this regulation. In addition to classic materials such as cardboard boxes or crates, the law also mentions other examples such as coat hangers, envelopes and glass bottles. The decisive factor, however, is that this is used for shipping the corresponding goods.

When coat hangers are shipped without clothing, the law thus does not define them as packaging. If the packaging is a protection or integral part that is required throughout the life or use of the product, it is also not packaging according to the definition of the law. Besides the actual packaging, the regulations governing the definition of packaging also include the filling material used for safe transport. In general, all packaging that you put into commercial circulation for the first time must therefore be licensed.

The obligation includes, for example, padded envelopes, bags, aids for padding (filling material) and shipping cartons as well as other components of packaging such as adhesive tape and shipping labels.
Licensing is only required once. A new licence does not have to be requested for product packaging that has already been licensed.

No licensing obligation for certain packaging

Some packaging is exempt from this obligation. It is also not necessary to provide a declaration of completeness here. According to Article 12 Paragraph 3 of VerpackG, this includes, for example, packaging subject to system participation that is not put into circulation in Germany. It must, however, be demonstrably clear without any doubt that these packaging materials are intended exclusively for export. Reusable packaging, disposable drinks packaging for which there is a mandatory deposit and other packaging are also not affected.

We will, of course, be happy to support you with registration and all obligations associated with the German Packaging Act.
Do you have any questions or need assistance? Get in touch with us easily now!

Important changes as of 1st January 2019

According to Article 9 of the German Packaging Act, anyone who places packaging and filler material on the market commercially for the first time will be subject to a registration obligation from January onwards. This registration must take place with Stiftung Zentrale Stelle Verpackungsregister before the first shipment. All registered companies are registered by the Zentrale Stelle. The new packaging register (LUCID) is published on the Internet as a list. Registration with the Zentrale Stelle is a mandatory requirement of the legislator, but may be carried out by third parties or an authorised representative in accordance with Article 33 of VerpackG.

The German Packaging Act: The new obligations at a glance

Video in German.

The new requirements on system participation (Article 7 of VerpacKG) are largely identical to the current provisions of the Packaging Ordinance. As a distributor, you are thus obliged to cooperate with commercial disposal companies (dual system) and make payments with which the dual systems finance the proper disposal of packaging (yellow bin, glass container, etc.). In addition to the previous regulations, from January 2019 the dual system must also be given the registration number, which will be communicated to you after registration with the Zentrale Stelle.

The most important change is undoubtedly the establishment of a central body (Stiftung Zentrale Stelle Verpackungsregister). This should support the enforcement authorities and ensure better transparency through strict market surveillance. The primary objective is the proper and sustainable disposal of packaging on a competition-neutral basis. To this end, the Zentrale Stelle assumes the following tasks in particular:

  • Registration of manufacturers (initial distributors) and experts
  • Registration and verification of systems and quantity reports
  • Monitoring of industry solutions (systems)
  • Registration and verification of the quantity flow certificates submitted by the systems
  • Recording of market shares of the systems
  • Individual decisions on particular types of packaging

With the new data reporting obligation according to Article 10 of VerpackG, you must also send Stiftung Zentrale Stelle all of the information sent to the dual system at the same time. What’s more, the period of system participation as well as the name of the system must also be communicated.

Specific obligations of retailers

Although the provisions of the law will only apply from 1st January 2019, the new developments are already relevant for retailers. This is primarily due to the obligation to register. Without registering with the Zentrale Stelle, it will no longer be possible to license packaging under the dual system in the future, so this process must be undertaken in advance. However, there are other obligations for retailers besides the obligation to register with the Zentrale Stelle and to register with a dual system.

In future, it will be necessary for you to communicate the total weight (mass) of the packaging you have placed on the market and the type of material to both the dual system and the Zentrale Stelle at the same time. However, the obligation to submit the declaration of completeness only applies if very small quantities are exceeded:

  • Cardboard, paperboard and paper = 50,000 kg
  • Glass = 80,000 kg
  • Plastics, aluminium, drinks cartons, ferrous metals & other composite materials = 30,000 kg.

This communication must be made at least once a year. By submitting a declaration of completeness to the Zentrale Stelle by 15th May each year, you will transparently present the total weight of the packaging you have placed on the market. This information must be certified by a registered inspector and then transmitted electronically. You can view a list of registered inspectors on LUCID.