Germany β LUCID, Packaging Register, Registration, Reporting π©πͺπ¦
In Germany, from 2022, all marketplaces must confirm compliance with the Extended Producer Responsibility (EPR) regulations, including the German Packaging Act, known as VerpackG. This means that this obligation applies to all sales channels, not just products sold via marketplaces.
Who is considered responsible? π€
All manufacturers and sellers are required to comply with the new German Packaging Act. These regulations apply to anyone who delivers packaging to Germany:
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- Online shop operators, including small retailers, who use packaging to ship the goods they sell π¦;
- Traders on sales platforms ποΈ;
- Brick-and-mortar retailers π¬;
- Manufacturers π;
- Importers π;
- Intermediaries.
What do we mean by packaging? ποΈ
For example, all types of paper packaging:
Paper π;
Paper bags ποΈ;
Plastics β»οΈ;
Disposable bottles made of glass πΎ;
Beverage cartons π₯€;
Aluminum π₯«;
Ferrous metals or other copper-based packaging π’οΈ;
Wool π§Ά;
Ceramics πΆ;
Wood π³;
Rubber β«.
Packaging also includes all primary, secondary, shipping and service packaging.
Thresholds π«
There are no set minimum thresholds for participation in the system.
Manufacturers’ obligations under the EPR in Germany π
Registration π
Since January 2019, all packaging manufacturers and first distributors have been required to register in the public database Zentrale Stelle Verpackungsregister (ZSVR) and must obtain a registration number. The special register for packaging in Germany is the LUCID Packaging Register.
Contract with the dual system (eco-operator or Producer Responsibility Organisation – PRO) π
The manufacturer is obliged to conclude a contract with one of the approved companies, which will take care of the disposal of the packaging.
Reporting π
Manufacturers must declare to the relevant Producer Responsibility Organisation (PRO) the sales of products subject to EPR. Reports must be provided in kilograms.
Reports are also submitted to LUCID, hence the name dual system.
Payment of fees πΆ
Manufacturers must pay eco-contributions determined by the PRO, depending on the EPR product category. The license fee can be from β¬ 25 per year and is determined based on the volume and type of packaging.
Authorised representative π₯
The manufacturer can choose a German representative to register the requirements of the Packaging Act on behalf of the manufacturer, but this is not mandatory.
Reporting deadline π
Reporting deadlines are set by the eco-operator. The deadline for the previous year is usually the end of March.
Penalties and sanctions β οΈ
If the manufacturer does not meet the obligation or provides incorrect quantities, penalties can be up to β¬200,000, with the possibility of a warning from the tax authority.
Get your EPR number in the countries where you sell your goods with packaging
π Schedule a free consultation at nowiconsulting. Take advantage of our comprehensive services:
– selection and signing of a contract with a representative,
– registration in the EPR system for packaging, electronic waste and batteries,
– legal services in the field of waste management (guidelines on marking, invoicing),
– reporting to recovery organizations.