Recovery & reporting of sales packaging: What changes from 1st January 2019

Meldung, Pfeil

Packaging can usually be found wherever goods are put into circulation. The new German Packaging Act governs how this is to be handled from 1st January 2019. This act stipulates that traders who bring packaging into circulation in Germany must register with the newly created Zentrale Stelle Verpackungsregister. They must also provide information on how they dispose of or recycle the packaging. The new law is intended to reduce the quantities of packaging waste while also making compliance with the statutory regulations more binding for everyone involved.

What is meant by sales packaging?

The term ‘sales packaging’ covers all packaging purchased by the end consumer together with the goods. This is referred to as a unit consisting of goods and packaging. Sales packaging also includes what is known as service packaging. This term refers to packaging used by retailers, restaurants and other service providers to enable or support the transfer of goods to private end consumers. This applies, for example, to bags for bread rolls and paper plates. Shipping packaging that enables the goods to be delivered to the end consumer by post is also included in sales packaging. Bubble wrap and other filling materials, which are primarily used in online retail, are also included in sales packaging.

What is the reporting of sales packaging and how does it work?

In order to comply with their obligation to dispose of and recycle sales packaging, traders generally conclude a contract with a waste disposal service provider such as Deutsche Recycling. When registering with Zentrale Stelle Verpackungsregister, manufacturers and retailers must indicate which service provider they are working with. A comparison is carried out by the database operators. When reporting sales packaging, traders must state which packaging they have disposed of, or will dispose of in the future, and to what extent via the service provider.

This includes:

  • A quantity report that provides information on the total quantity
  • The proportion of packaging and
  • The proportion of licensed packaging.

In administrative terms, this also includes accounting, reporting and documentation as part of correspondence with the central reporting office.

Good to know: According to the new German Packaging Act, registration and reporting may only be carried out by the company itself. In the future, it will no longer be permitted to enlist a third party for operational implementation!

What is Zentrale Stelle Verpackungsregister?

The new German Packaging Act stipulates that all manufacturers and retailers must register with Zentrale Stelle Verpackungsregister ( by 1st January 2019. The aim is to be in a better position to check whether all traders comply with their legal obligation to dispose of and recycle their packaging. In the past, it was mainly smaller traders from the online sector who were able to evade this obligation time and again. There was a lack of supervisory bodies and sanctions. This is set to change with the new German Packaging Act coming into force and the associated obligation to register.

The Zentrale Stelle Verpackungsregister also serves as consumer protection. It is publicly accessible to end customers on the Internet. The costs for maintaining the database are borne by the dual systems and other waste disposal service providers. The Zentrale Stelle Verpackungsregister is monitored by the German Environment Agency (Umweltbundesamt).

Who is obliged to register?

The obligation to register applies to all traders who are already obliged under the Packaging Ordinance to take care of the disposal and recycling of their sales packaging, insofar as this ends up with the end customer. This obligation applies regardless of whether the packaged products are offered for sale online or in a shop. The crucial factor is that the trader was the first to place the packaging on the market. Anyone who defies the obligation to register must reckon with severe fines and sales bans.

What does the Federal Government intend to do with the new law?

With the new German Packaging Act and the Zentrale Stelle Verpackungsregister, the state aims to reduce the quantities of packaging materials. This should also be achieved by means of financial incentives: it is expected that the costs for the disposal and recycling of environmentally friendly packaging will be lower than for poorly recyclable packaging, e.g. made from plastics. In addition, the new German Packaging Act and the obligation to register are intended to distribute the costs of disposal and recycling of packaging (e.g. sales packaging) more evenly among all of the manufacturers and retailers.