Packaging Licensing in Germany

German E-commerce platforms - Failure to comply with or fulfil the obligations set out in the Packaging Act (VerpackG) in Germany by e-commerce sellers may result in the closure of the shop.

Working with Der Grüne Punkt in Germany, we are here to help you succeed.

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New packaging law in Germany

In case you missed important information: the operator of an e-commerce platform must comply with this legal amendment to verify sellers if they comply with obligations of legal registration and system participation. If the sellers on the e-commerce platform is unable to provide this proof, the operator is obliged not to allow their sales on its platform of packages that do not participate in the system.

Important issues

Scan the QR code to apply for a packaging licence now

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How to comply with packaging law correctly?

1. EPR Registration
Register an EPR number with the Central Packaging Register on its LUCID website. To register, you will need to prepare information such as your company's business licence, contact person and contact details, brand information and all packaging types involved.

2. System participation (i.e. application for a packaging licence with a dual system)
Apply for a packaging licence with dual systems such as the Green Dot / Der Grüne Punkt (DSD) for the packaging that is required to participate in the dual system. A contract shall be closed with the dual system and the licence fee shall be paid based on the packaging materials and forecast weights you will be put in the German market.

3. Data reporting
Report your packaging data on the LUCID website of the German Central Packaging Register ZSVR. Login your LUCID account, choose “Data report” and select “Initial year volume report” or “Intra-year volume report” to submit the same packaging data you have licensed with your dual system. In the column of “System operator”, select “DSD (Der Grüne Punkt - Duales System Deutschland GmbH)” and save to complete the reporting.

What do I need to know about compliance with German packaging law?

The key to comply with German packaging law - system participation.
The German Packaging Act (VerpackG) specifies that all sellers who place packaging in commercial circulation on the German market must comply with the following THREE obligations:

  • Register an EPR number on LUCID, the official website of ZSVR
  • Apply for packaging licence for your packaging with dual systems (e.g. The Green Dot/Der Grüne Punkt/DSD)
  • Submit data reports to LUCID

The key to compliance is system participation.
For Chinese sellers exporting to the German market, simply registering an EPR number is
not enough to achieve compliance. It is also essential to sign a recycling contract with a dual system like Green Dot / Der Grüne Punkt and pay the licence fee for your packaging.

All obligations must be fulfilled before you put your packaging into German market.

Cross-border e-commerce sellers, whether using FBM, FBA or drop shipping, must comply with all the three obligations mentioned above under the packaging law before their goods cross the border into Germany. Failure to compliance results in the following consequences:

  • The e-commerce platform will prohibit your sales or distribution in Germany;
  • Fulfilment service providers (e.g. Amazon FBA) have the right to refuse services to any non-compliant clients;
  • Competitors can report you for non-compliance;
  • You may be subject to a fine of up to €200,000.

Why do I have to register my packaging and apply for a packaging licence?

Statutory amendments to German Packaging Act (VerpackG) have entered into force from 1 July 2022 that all packaging placed commercially on the German market must fulfil the obligations of registration, system participation and data reporting. Failure to do so may result in the following consequences:

  • The e-commerce platform will prohibit your sales or distribution in Germany;
  • Fulfilment service providers (e.g. Amazon FBA) have the right to refuse services to any non-compliant clients;
  • Competitors can report you for non-compliance;
  • You may be subject to a fine of up to €200,000.

What is the cost of packaging licence in Germany?

German packaging licence by Der Grüne Punkt starts from €25, depending on the packaging materials and the weights. You can go to VerpackGO by Der Grüne Punkt to calculate and estimate your costs and fulfil your obligation of system participation under the German packaging law.

What do I need to know about packaging licensing with Der Grüne Punkt?

When you license your packaging with Der Grüne Punkt, you need to know about:

• EPR registration number:

You must provide your EPR registration number to Der Grüne Punkt. If you do not have a registration number yet during your licensing, you can provide and update it on your Der Grüne Punkt’s customer portal later.

• Tax identification:

You can either provide your German tax number or German VAT number or your domestic tax number. VAT number is preferred and if you don’t have a VAT, you can also provide a Unified Social Credit Identifier of the country where your company is located.

• Cost of licensing:

The cost of licensing with Der Grüne Punkt depends on the packaging materials and the corresponding weights. You can estimate your licence cost directly on VerpackGO and follow the instructions on the website to complete the payment and licensing. Only when you have successfully paid the licensing fee, will you fulfil your obligation of system participation in dual system.

• After licensing:

Once you have paid for your Der Grüne Punkt packaging licence, you must also submit your data report to LUCID. Login your LUCID account, choose “Data report” and select “Initial year volume report” or “Intra-year volume report” to submit the same packaging data you have applied with your dual system. In the column of “System operator”, select “DSD (Der Grüne Punkt - Duales System Deutschland GmbH)” and save to complete the reporting.

In addition, you will receive a General Terms and Conditions, a summary of your licence with Der Grüne Punkt by email. You can also find out more details of your packaging licence on your Der Grüne Punkt’s customer portal.

How do I apply for my packaging licence with Der Grüne Punkt?

If you do not have a packaging licence with Der Grüne Punkt, you can apply one via VerpackGO by Der Grüne Punkt. Follow the step-by-step instructions on VerpackGO and complete payment in the final step.

Step-by-step guide for licensing:

1. Fill in information about the packaging you want to license
1.1 Select the year of your licence, i.e. the year you wish to start the contract with Der Grüne Punkt.
1.2 Choose your packaging materials and enter weights.
1.3 Select the type of contract with Der Grüne Punkt where system participation is mandatory. If you want to use the trademark of “Der Grüne Punkt”, you need to select "Trademark use". Check the estimated fee on the right and click "Checkout” to proceed to the next step.

2. Register for a Der Grüne Punkt portal account
2.1 Please fill in your company information and address, tax number, LUCID registration number and contact information in English or Chinese Pinyin.
2.2 Click “Next” to proceed to payment.
3. Confirm and complete the payment
3.1 Choose your payment method.
3.2 Check Summary of your data.
3.3 Read and agree to accept the Terms of Service, Privacy Policy.
3.4 Click "Conclude liable to pay" to complete the payment.

If you are already a customer of Der Grüne Punkt, you can log in to the customer portal to adjust and manage your packaging licensing at any time.

Do I have to have a German VAT number for packaging licensing with Der Grüne Punkt?

German VAT number is the preferred tax identification. If you do not have one, you can provide the tax number of the country where your company is based. In China, for example, this is usually the Unified Social Credit Identifier.

What information do I need to provide when licensing with Der Grüne Punkt?

To register for a packaging licence with Der Grüne Punkt under the German Packaging Act, you will need to prepare the following information:

  • Your packaging materials and weights;
  • Company name;
  • Street and house number;
  • Country;
  • Postal code;
  • Province and city;
  • Tax number (one of three options: German tax number or German VAT number or your domestic tax number);
  • LUCID registration number;
  • Contact information, including title, surname, first name, telephone number, language, email address;
  • Valid payment method (Alipay/Paypal/Credit Card (Visa or Mastercard only)/Bank Transfer, etc.).

How often should I license my packaging in Germany? / Does the German packaging need to be licensed monthly or annually?

The validity of packaging licence is based on each calendar year. The beginning and the end of each calendar year are critical timing for cross-border e-commerce sellers to comply with their packaging law obligations. It depends whether you license your packaging on an annual, quarterly or monthly basis.

For most small and medium-sized businesses, if your forecast packaging quantities do not differ
significantly from the actual packaging quantities you put into the German market, you can license your packaging annually.

For big corporates, if your packaging figures or sales vary significantly from month to month that it is difficult to accurately estimate the quantities for the whole year, then you can choose to submit a monthly or quarterly report on packaging quantities.

Do I have to license all my packaging?

Yes, all packaging must be properly registered and those subject to system participation must be licensed with a dual system like Der Grüne Punkt. For example, packaging that directly surrounds and protects goods and products, such as film, cardboard boxes, bags, etc., and secondary packaging, such as transport packaging, including carton, fillings, tapes and other materials that are used to secure the packaging.

Where should I register my packaging? What is the Central Agency Packaging Register?

The official website of Central Agency Packaging Register (ZSVR) - LUCID - has been put into use since January 2019. It assures the implementation of extended producer responsibility. Producers with valid packaging licence must register their companies and brands with ZSVR on LUCID. It is for the first time in Germany that such an organisation fosters transparency and legal certainty through its activities. The register makes it public who register and license their packaging and who do not.

Scan the QR code to apply for a packaging licence now

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