Packaging Act (VerpackG)

The Packaging Act (VerpackG) forms a legal framework that regulates the manufacture, sale and environmentally friendly disposal of sales packaging. The Packaging Act defines the responsibility for packaging in accordance with Section 23 of the Closed Substance Cycle Waste Management Act (KrWG).

A key consequence of this is the obligation of retailers, online retailers and manufacturers to actively participate in the disposal and recycling process. They are responsible for ensuring that the sales packaging of their products is disposed of or recycled in an environmentally sound manner.

What is the Packaging Act?

The Packaging Act (VerpackG) regulates the manufacture, sale and environmentally friendly disposal of sales packaging. In accordance with Section 23 of the Closed Substance Cycle Waste Management Act (KrWG), it defines the responsibility for packaging. Retailers, online retailers and manufacturers are therefore obliged to actively participate in the disposal and recycling process. This also includes the obligation for packaging licensing to ensure that their sales packaging is properly disposed of or recycled.

Packaging licensing

The Packaging Act includes packaging licensing, which affects manufacturers and initial distributors of packaging. According to the Packaging Ordinance, they must participate in a dual system or set up their own take-back systems, which requires registration and license fees. Use our online calculator to calculate your costs and license your packaging!

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Changes to the Packaging Act as of July 1, 2022

Innovations in the VerpackG

Since July 1, 2022, it is prohibited to sell packaged goods without timely registration by the manufacturer. Electronic marketplaces and fulfillment service providers take on new responsibilities.

They may only offer packaging if the corresponding mail order and online retailers have handled their packaging in accordance with the requirements and are registered in the LUCID packaging register. In addition, all manufacturers who bring packaged goods into circulation in Germany for the first time must register, regardless of the type of packaging.

Click here for registration instructions

VerpackG and costs

The costs associated with the Packaging Act can be diverse and depend on various factors:
-Licensing costs: Companies that place packaging on the market must participate in a dual system or set up their own take-back systems. This requires registration and the payment of license fees to these systems.

-Disposal costs: Disposal of packaging waste can incur costs, especially if it is not recyclable or reusable. Companies may need to invest in more efficient packaging solutions to minimize disposal costs.
-In addition, the Packaging Act includes the obligation to register in the LUCID packaging register, which does not initially incur any costs.

What types of packaging are covered by the VerpackG?

The revised Packaging Act also has an impact on transport packaging. In contrast to sales packaging, which is subject to a licensing obligation, transport packaging does not have to be licensed in the same way as packaging subject to system participation.
According to § 15 paragraph 1 of the Packaging Act, the following packaging is included: 

  • Transport packaging 
  • shipping packaging 
  • Sales and secondary packaging that does not typically end up with the private end consumer after use 
  • Sales and secondary packaging that is incompatible with the system in accordance with Section 7 (5) 
  • Sales packaging containing harmful substances 
  • Reusable packaging 
  • Service packaging 
  • Disposable beverage packaging subject to the deposit requirement pursuant to Section 31

Are you unsure whether your packaging is subject to system participation?

We will be happy to help you further:

If you have any questions, our customer service team is on hand with expert knowledge. We know the answers to your questions and are on hand with help and advice. Whether you are an SME or a small business: we are your partner for packaging licensing!

Data re­por­ting in ac­cor­dance with the Pa­cka­ging Act (VerpackG) 

In addition to registering with the Central Agency via the public portal LUCID, companies must also submit data reports. This means that any packaging licensed with a dual system such as zmart must be reported to the Central Agency without delay. As a dual system, we transmit the packaging quantities licensed with us to the Central Agency, stating your personal registration number, in order to identify any discrepancies in the quantities reported. Incorrect or omitted data reports can be subject to fines of up to 200,000 euros.

The reports that you must make directly to the Central Agency without the involvement of third parties include:

Planned quantity notification

Vor Beginn eines neuen Kalenderjahres lizenzieren Sie das gesamte systembeteiligungspflichtige Verpackungsmaterial, das Sie planen, im nächsten Kalenderjahr in Verkehr zu bringen. Davon ausgenommen ist das Verpackungsmaterial, welches bereits von Ihren Lieferanten lizenziert wurde.

Quantity adjustment

If you discover during the course of the year that you are putting more or less packaging material subject to system participation into circulation than originally planned, you can easily make these changes via our customer portal. This is known as a volume adjustment during the year.

Year-end report

At the end of a calendar year, at the latest at the beginning of the following year, you submit the year-end report to the ZVSR and your participating dual system. Here you can adjust your quantities once again and possibly obtain additional licenses so that the actual quantity finally includes all packaging quantities subject to system participation placed on the market during the year.

Declaration of completeness

According to the Packaging Act, companies are obliged to commission an approved expert from the Central Agency and submit a certified declaration of completeness if they exceed certain de minimis limits. These are 80,000 kg for glass, 50,000 kg for paper, cardboard and carton and 30,000 kg for all other materials.

Sustainability and circular economy

Objectives of the Packaging Act (VerpackG)

The objectives behind the Packaging Act (VerpackG) are to achieve responsible use of resources and to protect the environment.

These goals are to be achieved by:

  • Increasing the recyclability of packaging
  • Reducing packaging waste
  • Increasing recycling rates
  • Producer responsibility for the life cycle of packaging
  • Promoting the use of more environmentally friendly materials for packaging
  • Responsibility for collection, reuse and recycling
Who must license

VerpackG regulations according to use cas

For all companies placing goods on the market, there is an obligation to register the company and the associated brand names (including private labels) with the Central Packaging Register (ZVSR). For manufacturers and initial distributors of packaged goods, there is an obligation: Filled product packaging that accumulates as packaging waste at private end consumers and similar sources (e.g. hotels, hospitals, offices, etc.) must participate in the dual system, i.e. be licensed.


For drop shipments, the shipper of the goods is responsible for packaging licensing. Dropshippers should check whether the shipper complies with his system participation obligation according to VerpackG and request proof.

Imported goods

According to the law, the person who commercially imports goods into the scope of the Packaging Act is considered the first distributor. If an online retailer imports goods from China, for example, he is obliged to license all packaging material.

Own brands

Under the German Packaging Act, companies that market their own branded products are responsible for the proper licensing and registration of their packaging.

Marketplace Traders

Operators of electronic marketplaces must check whether the traders operating through them have properly licensed the packaging used. If proof cannot be provided, the trader in question will be banned from selling.

Produced in Germany

Packaging produced in Germany must be licensed by the party who first sells it filled with goods (exception: service packaging). For example, a manufacturer of detergent who sells to a retailer must license the product packaging.

Fulfilment partners

The commissioning retailer is responsible for packaging licensing. The fulfillment service provider has a control obligation: it must check whether the retailers acting through it fulfill their system participation obligation.

VerpackG: The most important facts

Who and what does the participation obligation apply to?

Every initial distributor of packaging, unless exempted under Section 12 of the German Packaging Act (VerpackG), is subject to system participation. All packaging must be licensed. This full registration includes sales, reusable and transport packaging.

What applies to service packaging?

Distributors of service packaging are also responsible for licensing the packaging they offer. However, there is also the option here of transferring system participation to the upstream distributor and purchasing packaging that is already licensed.

Where can packaging be licensed?

Packaging is registered via the LUCID register of the ZSVR, stating the required company data. You can conclude packaging licensing for your sales packaging with a dual system, such as the Zentek dual system.

What role does the ZSVR/LUCID play?

The Central Agency Packaging Register (ZSVR) checks compliance with the VerpackG. It maintains a public register (LUCID) in which companies, brands and private labels must be registered. In addition, data reports must be submitted regularly on the packaging subject to mandatory participation.

What is the public register?

The brand name and manufacturer must be registered with the ZVSR in the public register (LUCID). The packaging material that accumulates as packaging waste after use by the end consumer must participate in a dual system, i.e. be licensed.

What are the penalties for non-compliance?

Products from companies and brands that are not properly registered are banned from sale in Germany. This means that unregistered packaging and its contents may not be legally marketed, which has legal and economic consequences.