From 1 July 2022: Extension of the obligation to register packaging

From 1 July 2022, the registration obligation for manufacturers and distributors of packaging will be extended. Through this extended manufacturer registration, all packaging filled with goods, i.e. packaged goods that are placed on the market in Germany for the first time, must be registered at the Stiftung Zentrale Stelle Verpackungsregister / LUCID.

Classic packaging of this type is outer packaging that is coated and displays the contents with colourful product images, such as electronic devices as they are presented to the end customer on the shelf. It does not matter whether the packaging is subject to system participation or licensing obligations or not. The licensing obligation relates to "sales and outer packaging filled with goods that typically accumulates as waste at the private end consumer after use" (§ 3 para. 8 VerpackG).

The expansion of the Packaging Act also affects online marketplaces and fulfilment service providers. They are responsible for ensuring that the traders who sell their goods on the platforms comply with the new packaging law.

Which packaging is excluded from this? 

Transport packaging, reusable packaging and deposit-liable disposable packaging are not subject to system participation. However, manufacturers of this packaging must also be registered as manufacturers at the Stiftung Zentrale Stelle Verpackungsregister from 1 July 2022. Non-compliance may result in a distribution ban as of 1 July 2022.

Do you need help with the registration of your packaging? Please feel free to contact us.