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New Packaging Regulations to Germany

Diana Zheng
June 22, 2022

For our clients shipping particularly to Germany, a new packaging regulation will take effect starting on July 1, 2022

The updated version of this policy will impact Stallion users if you’re one of those who are shipping to customers in Germany. 

What is the Packaging Act?

Verpack G, also known as the German Packaging Act, pertains to those packaging only being disposed of after usage. Both small and large online businesses outside Germany are covered by this regulation.

On January 1, 2019, it took the position to replace the Packaging Ordinance. The German Packaging Act was derived from the 2018 revision of the European Packaging and Packaging Waste Directive.

The new ruling promotes the usage of recyclable packaging materials such as bubble wraps, cardboard boxes, and tape. Its primary goals are to conform to recycling quotas and offer monetary support in promoting sustainable packaging.

This initiative also encourages eCommerce sellers to take a step further in reducing packaging wastes, one shipment at a time. 

Packaging to be licensed

Generally labeled as ‘sales packaging,’ such materials include the following:

  • Repackaging materials
  • Service packaging materials
  • Shipment packaging materials

This category includes cardboard and stuffing materials.

Despite the categories provided, be informed that ALL packaging materials must be registered in LUCID. Therefore, it is not limited to the following packaging such as aluminum, cardboard and its composite materials, glass, natural materials, plastic, etc. 

Another thing to note is that one of our partner carriers, PostNL, reminds Stallion clients that the packaging doesn't have to be recycled. However, registering for LUCID is a must, as well as the compliance for the recycling fee to be paid.

Steps on how to register

The registration must be done before the said effective date. Take note of the following steps as your guide in registering for LUCID and other essential requirements:

Step 1: Register for LUCID, managed by the Central Agency Packaging Register (ZSVR)

After you sign up, you’ll get your own LUCID registration code that you will submit to your dual system. This procedure must be accomplished first before anything else.

Step 2: Get your license by selecting your preferred dual system.

Use the registration number you’ll get from Step 1 to have your license done. There are 11 dual systems for you to choose from:

There will be a corresponding license fee to pay to your chosen dual system, in which the amount depends on the volume and the kind of packaging used. The fee will usually cost only a few cents per kilogram. 

Step 3: Input the necessary details in LUCID.

It includes the name of your chosen dual system and your packaging quantity used for data reporting purposes.

Factors for noncompliance

The registration for LUCID is free, and every online retailer labeled as a manufacturer of the said packaging must sign up individually.

Failure to comply can lead to violator’s receipt of written warnings, heavier penalties of up to €200,000, and even sales prohibition. 

The packaging manufacturer can be charged fines up to €10,000 per infringement. Meanwhile, ‘free riders’ can be penalized up to €100,000 per case due to registration failure or by distributing products in which the manufacturer has not properly registered the brands they are distributing. Penalty may occur of up to €200,000 for manufacturers unwilling to participate in the said compliance.

Packaging Act Q&As

  • What is LUCID?

It is a platform created by the Foundation Central Agency Packaging Register where online sellers register. The Central Agency acquires, keeps, and carefully evaluates the data of the retailers and manufacturers. 

  • What is a dual system and what does it do?

A dual system is a private and authorized recycling enterprise that carries out the licensing obligation. They’re the qualified partner to whom online sellers pay for the licensing fee of the packaging materials you’ll be using.

  • For what purpose will the licensing fee be used for?

The licensing fees will be allotted for the budget of the recycling system.

  • Who is deemed as the manufacturer?

As the primary distributor in Germany, the manufacturer is obliged to register if they are operating for market purposes. 


Stallion Express does not offer legal advice in this kind of scenario. It is highly encouraged to seek a legal advisor for assistance on how you’ll undergo this shipping requirement.

It is highly advisable to seek assistance with ecosistant, a consultancy agency specializing in shipment compliance where eCommerce sellers can get the most suitable price for your packaging license. 

Meanwhile, if you’re an online seller shipping less than 1000 kilograms annually, you can compare the prices of all recycling systems using Verpackungs Lizenz 24’s pricing calculator

Learning resources to visit

German Packaging Act for Business Sellers – eBay 

VerpackG Packaging Act Requirements – Etsy 

VerpackG: How to Get Your Online Shop Compliant – eCommerce Germany 

Who is Affected by the German Packaging Act? – Lizenzero 

Shipping to Germany: Everything About The German Packaging Act –  Packhelp 

Packaging Act: Obligations at a Glance – ZSVR

Keep in touch with us at [email protected] or call our toll-free number at 877-863-7447, and our client support team will be happy to attend to your inquiries and concerns for the upcoming implementation of the German Packaging Act.

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