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The most important facts about the Packaging Act

The Packaging Act in a quick check

  • Anyone who is considered by the Packaging Act to be the first distributor of b2c packaging must license the packaging material.
  • The Central Packaging Register Office (Zentrale Stelle Verpackungsregister) monitors compliance with the Packaging Act. It maintains a public register in which every company subject to licensing must register. In addition, various reports must be submitted to the central office.
    • Quantity reporting after each licensing with a Dual System
    • Plan quantity notification for the next calendar year
    • Year-end report after each calendar year
    • Declaration of completeness (only for distributors of large quantities of packaging)
  • Products of improperly registered companies/trademarks may not be sold in Germany. The following points must be fulfilled:
    1. Brand and manufacturer must be registered with the central body.
    2. The packaging material was licensed with a Dual System
  • Violations of the law can be punished with fines up to 200,000 €.

What are the objectives of the Packaging Act?

In Germany, the following applies as a matter of principle: The person who puts packaging into commercial circulation who typically generates waste at the end consumer is responsible for the disposal of this packaging.

Of course, not every company can collect its packaging personally from the end consumer. This is why there are Dual Systems, which organise the disposal of the packaging via the yellow and blue bins as well as the waste glass containers and then take care of sorting and recycling. The Packaging Act creates a legal framework for every company subject to licensing to comply with it, e.g. the Central Office for Packaging Registers was established and entrusted with the task of monitoring compliance.

In the coming years, the Federal Government will examine to what extent the recycling quotas can be further increased.

This is intended to create a resource-conserving cycle in the future.

In addition, ecologically advantageous packaging, i.e. packaging that is easy to recycle, should cost less in licensing. This should create an incentive for companies to attach more importance to sustainable packaging materials.

The Packaging Act stipulates recycling quotas for dual systems:

PackingRecycling rate
as of 2019as of 2021
Glass, Aluminium & Metals80 %90 %
Paper/cardboard85 %90 %
Beverage containers75 %80 %
Other composite packaging55 %70 %
Plastic58,5 %63 %

Who needs to license?

In principle, all packaging that is typically generated by the end consumer as waste must be licensed. This also includes the shipping material.

The manufacturer or initial distributor of the packaging material is responsible for licensing. The manufacturer or first distributor is the person who commercially (possibly also free of charge) transfers the b2c packaging filled with goods for the first time to a third party with the aim of distribution, consumption or use.

Here are a few examples to illustrate this:

Goods produced in Germany

b2c products produced and sold in Germany are to be licensed by the person who first sells them filled with goods. An example: A producer of detergent who sells his b2c goods to a retailer must license the product packaging. In the next step, the retailer only has to license the packaging material which he himself uses additionally. This can be a shipping carton including filling material, but also a carrier bag.

Imported goods from abroad

It is regarded as the first distributor of goods imported into Germany from abroad. If an online retailer imports goods from China, for example, he is obliged to license the entire packaging material. If a trader from abroad sends his goods directly to the end consumer, the foreign trader must license the packaging material.

Own brands

Those who sell their own brands are responsible for licensing and registering the packaging.


In the case of drop shipments, the shipper of the goods is responsible for licensing the packaging material. Dropshippers are advised to check whether the shipper fulfils his obligation to participate.

Shipment by fulfillment partner

The decisive factor is who fills the shipping material with goods. If the goods are already finally packed and sent to the fulfillment center, which only adds the shipping label and sends the package, the online retailer must license the shipping material. If, on the other hand, the fulfillment center packs the goods in cartons or the like, the filmmaking partner must license the shipping material.

Can we help you?

We will be happy to advise you. Free of charge and without obligation.

Give us a call:
+49 2203 8987 700 (Mo. – Fr. 09:00 – 17:00 Uhr)

Or send us an e-mail:

Which reports do I have to submit?

In addition to registering with the central office, you must also submit quantity reports to it. Any quantity that you have licensed from zmart must be reported immediately to the central office via the LUCID online portal. As a dual system, we must also notify the Central Office of the quantities of packaging you have licensed from us, taking into account your personal registration number. It is therefore possible to determine whether there are deviating quantities. Wrong or not submitted quantity reports can be punished with fines up to 200.000 €.

Planned quantity

In practice, the process is usually as follows: Before the beginning of a new calendar year, smaller companies license all the packaging material that they plan to put into circulation next year. Should you find out in the course of the year that you will circulate more packaging material than originally planned, you can simply re-license packaging material in our customer portal. After licensing the planned quantity, as well as if you have subsequently licensed quantities, you report the licensed quantities to the central office. You may not report the packaging material that has already been licensed by your suppliers to the Central Office.

Year-End Report

At the end of a year, but by the beginning of the following year at the latest, you must submit a year-end report to the Central Office and to us. This report includes all packaging quantities placed on the market during the year. Here you have again the possibility to adjust your quantities and to license them afterwards.

Declaration of completeness

Certain companies must also submit a certified declaration of completeness. This notification is mandatory if the following minor limits are reached:

  • Glass: 80,000 kg
  • Paper and cardboard: 50,000 kg
  • All other materials: 30.000 kg

Certain companies must also submit a certified declaration of completeness. This notification is mandatory if the following minor limits are reached:

If you do not reach the above quantities, you are exempt from submitting a declaration of completeness, but in case of doubt, the Central Office may nevertheless require you to submit such a declaration. All declarations must be made by you personally and may not be made to a third party.

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