The Packaging Act in practice
The Packaging Act (VerpackG) ensures that packaging waste generated by private consumers in Germany is recycled. The aim is to protect the environment and promote the circular economy (Section 1 VerpackG). Anyone who puts packaging into circulation must register and license it. This guide explains the rules for six typical cases: dropshipping, imported goods, private labels, marketplace retailers, goods produced in Germany, and fulfillment partners.
Dropshipping
In dropshipping, you sell goods online without storing or shipping them yourself. The manufacturer or wholesaler sends the goods directly to the customer. According to § 3 (8) VerpackG, packaging is “placed on the market” when it is offered or provided in Germany for the first time. The “manufacturer” (§ 3 (14) VerpackG) is the person or company who fills the packaging with goods or is named as the sender on the packaging. In dropshipping, this is usually the producer or wholesaler, not the retailer. Therefore, you do not have to license the packaging (§ 7 VerpackG) or register with the Central Packaging Register (ZSVR) (§ 9 VerpackG) if your name does not appear on the packaging.
However, if your name appears as the sender (e.g. on the shipping box), you are considered the manufacturer. In this case, you must license the packaging through a dual system (§ 7 (1) VerpackG) and register with the ZSVR (§ 9 (1) VerpackG). Since July 1, 2022, you must also prove to marketplaces like Amazon that your packaging is licensed (§ 9 (5) VerpackG). Failure to do so may result in a sales ban (§ 36 (2) VerpackG). Request written confirmation of licensing from your producer or wholesaler to be sure.
Imported goods
If you import goods from abroad into Germany, you are considered the manufacturer (§ 3 (14) Sentence 2 VerpackG) because you bring the packaging under the scope of the law. This applies to all packaging that becomes waste for private end consumers, such as product packaging (e.g. plastic around toys) or shipping boxes (§ 3 (1) VerpackG). You must license this packaging with a dual system (§ 7 (1) VerpackG) and register in advance with the ZSVR (§ 9 (1) VerpackG). The registration gives you a LUCID number, which is required for licensing.
Example: You import clothing. Whether from within or outside the EU, you are responsible for all packaging that ends up with customers in Germany. If you purchase goods "delivered free to customer" and the foreign supplier ships directly, you must clarify who is licensing the packaging. Without a clear agreement, the responsibility falls on you. If your packaging quantities exceed certain thresholds (e.g. 80,000 kg of glass or 50,000 kg of paper annually), you must submit a completeness declaration (§ 11 VerpackG). Violations may result in fines of up to €200,000 (§ 34 (1) No. 1 VerpackG).
Private Label Products
Private label products are goods sold under your own brand name, such as food or cosmetics with your logo. If you place these products on the market in packaging in Germany, you are considered the manufacturer (§ 3 (14) No. 1 VerpackG). You must license all packaging that ends up with the end consumer through a dual system (§ 7 (1) VerpackG) and register with the ZSVR (§ 9 (1) VerpackG). This also applies if the products are manufactured abroad and you import them into Germany.
Example: You sell coffee under your own brand, packed abroad. As the importer, you are responsible for licensing the coffee packaging and shipping boxes. If a foreign producer ships directly to your customers, you must ensure the packaging is licensed or contractually transfer the obligation to the producer. Since July 1, 2022, you must prove to marketplaces that your packaging is licensed (§ 9 (5) VerpackG). Without proof, a sales ban may be imposed (§ 36 (2) VerpackG).
Marketplace sellers
If you sell on online marketplaces like Amazon, eBay, or Otto, the same rules apply as for other online sellers. If you place packaging on the market, you are the manufacturer (§ 3 (14) VerpackG) and must license it (§ 7 (1) VerpackG) and register with the ZSVR (§ 9 (1) VerpackG). Since July 1, 2022, marketplace operators must verify that you fulfill your obligations (§ 9 (5) VerpackG). This means you must provide your LUCID number and proof of packaging licensing. Without this proof, your products cannot be sold (§ 36 (2) VerpackG).
Example: You sell electronics on Amazon. You are responsible for the product packaging (e.g. plastic wrapper) and shipping box if you ship it yourself. If you use a fulfillment service provider, you must either license the packaging they use or obtain proof of their licensing. Violations may result in fines of up to €200,000 (§ 34 (1) No. 1 VerpackG).
Products manufactured in Germany
If you produce goods in Germany and sell them in packaging, you are the manufacturer (§ 3 (14) VerpackG). You must license all packaging that becomes waste for end consumers through a dual system (§ 7 (1) VerpackG) and register with the ZSVR (§ 9 (1) VerpackG). This includes product packaging (e.g. yogurt cups), outer packaging (e.g. boxes around multiple units), and shipping packaging (e.g. tape, void fill) (§ 3 (1) VerpackG).
Example: You produce cookies in Germany and ship them to customers. You are responsible for all packaging waste incurred by the customer. If you sell to resellers, the product packaging (e.g. cookie wrapper) remains your responsibility, while the reseller licenses the shipping packaging. If your packaging quantities exceed certain thresholds, you must submit a completeness declaration (§ 11 VerpackG). Violations may result in fines (§ 34 (1) VerpackG).
Fulfillment partners
Fulfillment service providers store, package, and ship goods for sellers without owning the goods themselves (§ 3 (14c) VerpackG). Since July 1, 2022, they are no longer responsible for licensing shipping packaging (§ 7 (7) VerpackG). This duty falls on you as the seller if you place the goods on the market (§ 3 (14) VerpackG). You must license the packaging used by the fulfillment partner (§ 7 (1) VerpackG) and register with the ZSVR (§ 9 (1) VerpackG).
However, the fulfillment partner must check whether you have met your obligations (§ 9 (5) VerpackG). Without proof of your LUCID registration and packaging licensing, they are not allowed to provide services for you (§ 36 (2) VerpackG). Make sure to license all packaging used and provide documentation to your fulfillment provider.
Conclusion
The Packaging Act (VerpackG) stipulates that all packaging that becomes waste for private end consumers must be licensed (§ 7 (1) VerpackG) and registered with the Central Packaging Register (ZSVR) (§ 9 (1) VerpackG). Who qualifies as the manufacturer depends on who first places the packaging on the market in Germany (§ 3 (14) VerpackG). In dropshipping, licensing responsibility usually lies with the producer or wholesaler—unless your name appears on the packaging. Importers and private label sellers are fully responsible for product and shipping packaging, especially for goods coming from abroad. If you manufacture in Germany, you must license all packaging that ends up as waste with your customers. Marketplace sellers and fulfillment partners must provide proof of compliance with VerpackG obligations (§ 9 (5) VerpackG), or risk sales bans (§ 36 (2) VerpackG). If your packaging volumes exceed certain thresholds, you must submit a completeness declaration (§ 11 VerpackG).
To avoid fines of up to €200,000 (§ 34 (1) VerpackG), you should carefully review your obligations. Clarify responsibilities contractually with suppliers or service providers—especially in dropshipping or fulfillment scenarios—and collect proof of packaging licenses. Registration with the ZSVR provides you with a LUCID number, which is essential for licensing and for demonstrating compliance to marketplaces. Use dual systems to ensure proper licensing of your packaging. In doing so, you protect your business and actively contribute to a circular economy, as required by § 1 VerpackG.