The new German Packaging Act is coming – and it’s particularly important for online retailers

As from 1 January 2019, the new German Packaging Act (VerpackG) will replace the current German Packaging Ordinance. For operators of small online shops, particularly, this will entail important questions regarding sales packaging and secondary packaging, transport packaging and packaging materials. But terms like mandatory participation, mandatory registration and the newly created “Central Packaging Registry” need to be clarified. To enable you to stay on top of these issues, we have summarized the most important information here in an easily comprehensible form.

First of all: the new German Packaging Act applies for all distributors who put packaging into commercial circulation in Germany for the first time (referred to as “manufacturers”) – i.e. both for national producers and for importers, online dealers, etc. The act contains some new regulations and duties or their modification. We will be pleased to answer the questions of relevance for you:

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What is mandatory participation?

If you are selling or otherwise putting into circulation goods via your online shop, you have to arrange for your sales packaging and secondary packaging to participate in a dual system. The latter will in return arrange for the packaging to be collected and recovered after use. This is why you have to arrange for your packaging to participate in a dual system (sometimes this is also called “licensing”). You can comply with this “duty of system participation” by registering with Der Grüne Punkt, for example.


How does the duty of system participation function?

You also state the new registration number with the dual system at which you register your packaging. “System participation” for the years as from 2019 will run under this registration number. Important: your packaging is also subject to mandatory participation under the currently applicable German Packaging Ordinance, of course – after all they are already being separately collected and recovered. You haven’t registered your packaging yet? Then use Registration with Der Grüne Punkt, for example.


How do I have to report to the Central Packaging Registry?

Almost all the particulars you gave within the framework of your system participation have to be communicated by you yourself directly to the Central Packaging Registry – but at least:

  • Name, address and contact data of the manufacturer
  • Details of a natural person with powers of representation
  • National ID number of the manufacturer, including the European or national tax number of the manufacturer
  • Brandnames under which the manufacturer is putting into circulation his packaging subject to mandatory system participation
  • Declaration that the manufacturer concerned is meeting his take-back duties by participating in one or more systems or through one or more sectoral solutions
  • Declaration that the particulars given are true

Please note: You have to do this yourself. Because for registration under § 9 VerpackG and for submitting data reports under § 10 VerpackG, no third parties may be commissioned (see § 33 VerpackG)!


What is mandatory registration?

By the time the new act comes into force at the latest, you also have to register with the new “Central Packaging Registry”– you have to do this before you dispatch anything for the first time. This is because you are definitely not permitted to put into circulation packaging not properly registered. You can apply for the requisite registration number in good time before 1 January 2019 under


What is the purpose of these new duties, and what is the remit of the Central Packaging Registry?

Nowadays, far more packaging are separately collected and recovered than are actually being reported at the dual systems. There are various reasons for this. Many companies, particularly small ones, do not know their duties under the German Packaging Ordinance and the new German Packaging Act. With the new rules, though, it will be easier to reconstruct which packaging have been registered (i.e. are participating in the dual system) and which haven’t.

The advantage is this: the more packaging participate in the dual system, the wider the financial base is – which means the costs are shared among more shoulders, rendering it more affordable for a single company. So in the long run everybody benefits.

The coordinating body here is the newly created Central Packaging Registry. It is an incorporated foundation under civil law, with a remit including the following tasks:

  • Registration of manufacturers before goods are first put into circulation
  • Receiving data reports from manufacturers and systems
  • Filing Declaration of Completeness
  • Maintaining a register of inspectors (expert appraisers, auditors, tax consultants, chartered accountants)

You will find further information about the Central Packaging Registry on the following website


Declaration of Completeness

We’re nearly finished now. The systematized procedures for the Declaration of Completeness and the de-minimis limits (§11 Para. 4 VerpackG) remain the same. You will be exempted from the duty to submit a Declaration of Completeness if you have put into circulation less than 80 tons of mandatory-participation packaging made of glass, less than 50 tons of paper, board or cardboard and less than 30 tons of a different material. Thus most companies will not have to submit a Declaration of Completeness.

There are, however, also the following new provisions, which you will have to keep an eye on:

  • The submission deadline for your Declaration of Completeness will be extended: instead of 1 May -> new 15 May (if your quantity of packaging is below the de-minimis limit, the extension is not relevant for you)
  • Your Declaration of Completeness may be checked only by registered expert appraisers, auditors, tax consultants or chartered accountants
  • Quantitative deductions due to damaged or unsaleable packaged goods that did not get as far as the consumer are possible only if both take-back for each individual case in verifiable form, and arrangements for recovery in accordance with the relevant recovery requirements are evidenced by appropriate documentation

The procedure for your registration in overview:

Here you can once again easily trace all the steps you have to keep in mind:

The procedure for your registration

Ambitious increase of recycling targets

The current legal minimum recycling targets have been increased in all material categories. The take-back system has to prove in the mass flow verification re-port once a year that these targets have been achieved.

Recycling targets

What incentives are there to use ecologically advantageous, recyclable packaging?

Sustainability will be even more worthwhile in future: the dual systems are under the new German Packaging Act called upon to encourage packaging that are particularly amenable to recycling or are produced from recyclates or renewable raw materials. This means that in the medium term calculation of the participation fees will be governed by ecological criteria.

Even today, many packaging can already be designed to meet these criteria. Der Grüne Punkt will be pleased to assist you in regard to recycling-friendly design, product development, and optimization of your packaging, or will advise you on using high-quality recyclates.


How will the mandatory deposit arrangements be extended?

The mandatory deposit arrangements, too, will once again be extended. Non-returnable beverage packaging of carbonated fruit and vegetable squashes and mixed drinks with a whey content of at least 50 percent may in future be sold only against a deposit of 25 cents. Moreover, returnable and non-returnable products must be clearly designated as such on the supermarket shelves.

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You will find more information on the German Packaging Act here.

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FAQ Packaging Act


Here you can find all the necessary answers about the packaging act.

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