Take-back and recycling of sales packaging – what does the new law bring?


When goods are put into circulation, sales packaging is required. This must then be disposed of properly. The new German Packaging Act (VerpackG) has regulated the correct handling of this, including take-back and recycling, since 1st January 2019.

What is sales packaging?

Sales packaging is defined as anything that does not belong to the product in the proper sense and is generated by the buyer as waste. This includes all product packaging such as cans, boxes, blister packs, bags and the like. However, shipping packaging such as shipping cartons, filling material, adhesive tape and packaging materials also fall into this category.

All manufacturers and retailers who bring sales packaging into circulation with their goods in Germany are obliged to take back or recycle this packaging. This is stated in the current Packaging Ordinance and nothing will change here with the new German Packaging Act.

What does the new German Packaging Act bring?

One important change is the Zentrale Stelle Verpackungsregister (ZSVR). One of the main tasks of this newly created institution is the introduction of the central packaging register LUCID. With LUCID, the Zentrale Stelle manages a transparent register that can be viewed by the public. All national manufacturers, importers and mail-order companies must register here. Anyone who produces, sells or delivers packaging is obliged to do this. Companies that fail to comply with their obligations are threatened with fines and a distribution ban for the packaging. The aim is to distribute disposal costs fairly. In addition, the ZVSR decides which packaging must be included in LUCID and is the central point of contact for companies.

Preventing packaging waste as part of product responsibility remains a top priority. Where this is not possible, the packaging should be recycled. Costs for packaging that is particularly easy to recycle are to be reduced in future. This is intended to create financial incentives for companies.

What obligations apply to retail with regard to the take-back and recycling of sales packaging?

Manufacturers and distributors are obliged to take back and recycle sales packaging.

Take-back in cooperation with a dual system

Dual systems help you as a retailer create a concept. This applies to the collection of plastics, paper, card, cardboard boxes and more. The return of drinks packaging is also organised in this way. The service provider assumes responsibility for collection and environmentally friendly disposal.

However, in addition to taking back and recycling sales packaging, numerous administrative activities still have to be carried out:

  • A quantity report must provide information on the total quantity, the proportion of packaging and the proportion of licensed packaging.
  • Accounting, reporting and documentation as part of correspondence with the central reporting office.

Service solutions from a single source

Licensing and taking back sales packaging involves additional work and time for many manufacturers and retailers. It is not always easy to meet these obligations in addition to running a business. Anyone wishing to place this task in experienced hands is well advised to contact specialised service providers such as Deutsche Recycling. A solution tailored to your requirements means that sales packaging is no longer a problem for your company. You gain legal security with regard to licensing and the return of packaging, and have full control over costs and personnel expenses.