Foreign businesses placing packaged goods on the German market face several legal duties under the country’s packaging law.
These obligations apply even if a company has no physical presence in Germany, as long as its products reach German consumers.
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The rules focus on registration, system participation, and ongoing reporting, all overseen by the Zentrale Stelle Verpackungsregister (ZSVR) through the public LUCID Packaging Register.
Register with the lucid packaging register
Any company that first introduces packaged products into the German market must register in the LUCID Packaging Register before shipping goods.
In the law, a “producer” can be a manufacturer, importer, brand owner, online retailer, or any actor placing packaging into circulation for the first time.
Since 2022, this registration duty applies to all packaging types, from retail and shipment packaging to industrial and reusable formats. Registration results in a unique LUCID number that becomes publicly visible.
Operating without a valid registration can result in significant penalties and potential sales bans.
Join a dual system if your packaging reaches consumers
Foreign sellers must determine whether their packaging is subject to system participation. If it ends up with private final consumers — such as household waste — it must be licensed through a recognised dual system.
This requirement covers retail packaging, grouped packaging, and shipment packaging used for e-commerce deliveries.
To comply, companies must sign a system participation agreement with a dual-system operator and pay fees based on the material and volume of packaging placed on the market.
These fees fund nationwide collection and recycling services. If selling through online marketplaces or fulfilment providers, foreign companies should be aware that these platforms are now required to verify compliance.
Report packaging volumes to lucid and your system operator
Once registered and licensed, companies must report their packaging volumes. Data must be submitted both to the selected dual system and to LUCID, with identical figures across both submissions.
Reporting frequency depends on the contract with the system operator, and businesses can update expected volumes during the year if necessary.
Larger companies may also be required to file a declaration of completeness — an audited statement of all packaging distributed in the previous calendar year — to demonstrate full compliance.
Foreign sellers entering the German market must treat the VerpackG as a compulsory framework. The law supports producer responsibility and aims to ensure that companies contributing to packaging waste also contribute to its recovery.
Non-compliance is publicly visible in LUCID and carries financial and reputational risks, making early registration and accurate reporting essential for any international business trading in Germany.
