Extended Producer Responsibility (EPR) for Packaging in Germany

Enacted in 2019, the German Packaging Act (VerpackG) incorporates the principle of extended producer responsibility, and therefore requires all merchants and manufacturers who distribute products to German consumers, and who accordingly place packaging on the market in Germany, to share the costs of disposal and recycling for this packaging. The law applies to all companies, regardless of their size, registered place of business or packaging quantities.

In practice, sharing the costs of packaging recycling involves licensing packaging with a dual system (and is therefore also known as system participation). This licensing is mandatory for all merchants and manufacturers who place sales packaging on the market. Packaging must always be licensed when a merchant or manufacturer acts as an ‘initial distributor’ and places packaging materials on the market in Germany that ultimately end up being disposed of as waste by a consumer.

Specifically, this means that any company that

• fills the packaging itself,

• commissions it to be filled (e.g. by using a fulfilment service provider) or

• brings the packaging together with its imported goods onto German territory

is affected by the Packaging Act and must license the packaging.

To do so, affected merchants declare the planned packaging quantities and materials with a dual system provider and pay the licensing fee that then becomes due.

Following an amendment to the German Packaging Act, Amazon and other marketplaces now have a duty of control that must be completed by July 2022: they are responsible for confirming that merchants who ship their products to German consumers have licensed their packaging. Accordingly, marketplaces now require forms of proof (EPR registration number and proof of participation in a dual system), which must be uploaded to the merchant’s account. From July 2022, any merchants who have not complied with licensing rules can expect their accounts to be blocked.

Compliance is coming: From July 2022, anyone using marketplaces to sell to German consumers will need to be fully licensed!

You need to do the following:

…if you distribute packaged products to German consumers:

1. License your packaging quantities with a dual system: Apply now for your licensing agreement

2. Register as a ‘producer’ with the LUCID register maintained by the Central Agency Packaging Register (ZSVR): Register here

3. Enter the name of the dual system and the licensed quantities in the LUCID register

Important: Don’t worry too much about the legal term ‘producer’ here. Merchants who are the first to place packaging on the market in Germany are also considered ‘producers’ in a legal sense.

Your EPR number: Once you have completed the LUCID registration process, you will receive your individual registration number, which you then need to submit to your marketplace as your EPR number. Your proof of packaging licensing/system participation will be issued to you by your dual system.

…if you distribute packaged products to consumers in other European countries:

The legislation governing packaging registration varies across Europe.
Each country has its own rules and individual system providers (EPR registration partners) who are needed to ensure compliance for packaging placed on the market.

For an overview, visit the information portal Lizenzero.eu, which offers guidance for each destination country.

What packaging do I need to license?

All packaging materials without exception are subject to the system participation / licensing requirement if they are used commercially and end up being disposed of as waste by end consumers. This includes product packaging, secondary packaging, shipping packaging and service packaging. Licensing is also required for the filling and padding materials used in shipping cartons, for example (especially relevant for e-commerce businesses), and packaging aids such as shipping labels or parcel tape. When it comes to licensing, the actual type of material involved is irrelevant: licensing (system participation) is required for all materials. Examples of materials that need to be licensed include:

• Paper, paperboard and cardboard: Shipping cartons, folding cartons, packing paper and paper bags

• Plastics: Plastic bottles, plastic bags, wrap, cups, blister packs, pots

• Glass: Non-returnable containers for food, beverages and medicines

• Beverage cartons: Beverage cartons are made from cardboard and a very thin layer of plastic or aluminium

• Ferrous metals: Tins, beverage cans, tubes and bottle caps.

• Aluminium: Bottles and cans, bottle closures, wraps and tubes.

• Other materials: Packaging and containers made from ceramics, copper, wool, wood and rubber.

• Other composite packaging: Packaging made from at least two distinct materials that are joined together across their entire surface area (e.g. vacuum packs for coffee).

When do I become responsible as a merchant?

  • Whether your company is domiciled within or outside Germany, the German Packaging Act makes you responsible for ensuring the participation (licensing) of the following packaging with a dual system:

    • Product packaging – including all constituent parts
    • Shipping packaging – including filling materials/packaging aids

  • The Packaging Act makes you responsible for ensuring the participation (licensing) of the following packaging with a dual system:
    • Product packaging – including all constituent parts (exception: the merchant/manufacturer can provide proof that product packaging is already part of a dual system higher up the distribution chain)
    • Shipping packaging – including all filling materials/packaging aids

    You are not responsible for the following packaging (exception: you yourself add constituent packaging parts):
    • Product packaging previously filled by the merchant/manufacturer


  • The Packaging Act makes you responsible for ensuring system participation for the following packaging if you are responsible for the imported goods as they cross the border into Germany:*

    • All packaging and its constituent parts that are brought onto Germany territory along with the goods themselves
    • All other packaging that you add yourself and therefore place on the market

    * Since an importer actively brings goods into Germany, the importer is normally the person who is legally responsible for the goods as they cross the border; other arrangements should be contractually agreed between the business partners.


  • Whether your company is domiciled within or outside Germany, the German Packaging Act makes you responsible for ensuring the licensing of the following packaging with a dual system:
    • Product packaging – including all constituent parts (exception: the merchant/manufacturer can provide proof that product packaging is already part of a dual system higher up the distribution chain)
    • Shipping packaging – including filling materials/packaging aids

    Important: Alongside marketplace operators, fulfilment service providers must also receive proof of EPR from their merchants by July 2022: if no proof is given, the service provider is prohibited from storing, packing or shipping their goods.

Do you also ship your products to other countries? Watch out!

Every country in Europe has its own packaging guidelines and processes for licensing. Traders who do not comply can face painful sanctions. Fulfil your obligations now in all your export countries quickly and easily. You can choose whether you want to use the practical and inexpensive action guidelines that guide you step by step through your to-do's for each country after an obligation check, or hand over the licensing completely to the licensing service via the power of attorney model and sit back and relax.

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