Due to Germany’s extensive Environmental Legislation, there are recycling obligations on manufacturers and distributors towards packaging, waste electronics and batteries.
Fortunately, the Chamber offers British companies a practical consultancy service to explain their obligations under German Law and to simplify the application and reporting procedures to many of the schemes.
Our dedicated German-speaking experts will get to know your company and its products, advise which legislation will apply to you and take you through the next steps to ensure that you are meeting your obligations and submitting the relevant documentation.
The German Packaging Law VerpackG obliges manufacturers and distributors to take back used, empty sales packaging from consumers free of charge and to forward it for recycling, regardless of whether they sell direct, via retailers, wholesalers or importers.
Sales packaging is understood to be anything that helps with the containment, protection, handling, delivery or presentation of goods.
The easiest way to determine what is sales packaging is to establish if the packaging in question is discarded by the consumer/end-user. Basically, this is anything a consumer takes home with him upon purchase or receives through an online purchase (e.g. cartons, cans, tubes, jars, pots, polystyrene moulds and chips, bubble wrap, plastic bags, cardboard boxes etc.). End users are private households, but also small businesses (hair salons, bakeries, butchers’ shops, pharmacies etc.), schools, hospitals, old people’s homes, hotels, restaurants and other comparable institutions.
For all obligated companies, there is compulsory membership of a dual system (compliance scheme), which ensures that used sales packaging is regularly collected from end users.
For many years, the German-British Chamber has been advising British companies on how to comply with the many aspects of German environmental legislation. We work closely with different compliance schemes to give British exporters a real choice of systems, suited to their needs.
If you are selling in Germany and require advice on your sales packaging obligations, please complete and return the enquiry form and we will be in touch.
Packaging such as cardboard outers, pallets or shrink wrap, which is discarded by the wholesaler or retailer, is classified as transport packaging. Our service does not currently cover transport packaging but please speak to us if you require assistance.
NEW from 2019: the Packaging Register LUCID
From 2019 companies must register with LUCID and obtain a registration number before placing packaging onto the German market.
In addition to reporting their packaging data to their chosen recycling scheme, companies must also report the same data to LUCID, at the same time and frequency they are reporting to their recycling scheme.
Companies that complete a Declaration of Compliance must file this with LUCID from 2019. The new deadline is 15 May.
Compliance Schemes for Sales Packaging
Companies must declare to their compliance scheme the weights of each material type for the sales packaging they put into the waste stream in Germany.
It is important to have details of weights and materials for each product’s sales packaging sold in Germany. These figures, with the sales figures for each product, are the basis for the data submissions.
The annual volumes of sales packaging put into the German waste stream dictate how often sales packaging must be declared – monthly, quarterly or annually. The more sales packaging is distributed, the more often the data must be submitted to the compliance scheme. Companies with high volumes of sales packaging report more often – quarterly or monthly – and companies with lower volumes report annually.
Please also see the section on the new German Packaging Register LUCID, as your company will need to obtain a LUCID registration number to be able to participate in a recycling scheme.
The German-British Chamber works with a number of compliance schemes in Germany and we can assist you in being compliant with the legislation. For more information, please complete and return the enquiry form.
Green Dot Logo
The Green Dot logo – two interlocking green arrows forming a circle – is no longer mandatory in Germany.
In previous years companies were required to display the logo on sales packaging to indicate that it was registered with a compliance scheme. This is still the case in some EU countries.
If your packaging in Germany is to display the Green Dot logo, you will need a trade mark contract with Duales System Deutschland, which owns the licence there.
For more information, send us an email.
Declaration of Compliance (Vollständigkeitserklärung)
A Declaration of Compliance (DOC) is a verification of the volumes of sales packaging placed into the German market by a manufacturer/distributor within one calendar year.
This documentation is in addition to the regular data submissions for your sales packaging to Germany and must be audited by a tax consultant, auditor, certified accountant or independent expert and verified by electronic signature.
A DOC is based on minimum volumes. The certified Declaration of Compliance is to be submitted each year, if one of the following volumes of packaging placed into the market are exceeded:
Glass › 80,000kg/year
Paper, card, cardboard › 50,000kg/year
Other (Aluminium, plastic, compounds, tinplate) › 30,000kg/year
As soon as one of these limits has been exceeded, a DOC must be submitted for all packaging materials.
From 2019 the data must be submitted to the new Central Packaging Register LUCID by 15 May each year.
Bottles: Compulsory Deposit Scheme
Drinks manufacturers should also be aware that there is a compulsory deposit scheme in operation in Germany for drinks containers such as one-way glass bottles, one-way PET bottles and beverage cans from 0.1 litres to 3 litres.
This includes all beer, mineral water, carbonated and non-carbonated soft drinks and alcoholic mixed drinks (e.g. alcopops).
The new Packaging Law VerpackG, which comes into force on 1 January 2019, extends the mandatory deposit for single-use beverage packages to carbonated fruit and vegetable nectar.
The new law also obliges the final distributor to label the shelves as „ONE WAY“ or „RETURNABLE“ beverage packaging.
Packaging for milk, wine and fruit juices that isn’t covered above, as well as ecologically advantageous packaging such as drink cartons, polyethylene tubular bags and stand-up bags remain exempt from deposit but are still subject to the recycling obligations under the Packaging Law.
For information on the deposit scheme, please visit DPG Pfandsystem.
Waste Electronic and Electrical Equipment and Batteries in Germany
With the introduction of the Electrical and Electronic Equipment Act (ElektroG), consumers in Germany are able to return old radios, computers and other electrical and electronic equipment (EEE) to local collection points free of charge. Producers are then obligated to take back the equipment collected and to dispose of it.
The law was amended in August 2018 to cover goods with an electrical/electronic function, e.g. furniture and clothing with electrical/electronic function, and introduced changes to the categories of equipment to be registered.
The Batteries Act (BattG) in Germany aims to reduce the environmental impact of batteries and applies to all types of batteries and accumulators/secondary batteries, i.e. automotive batteries, industrial batteries and rechargeable and non-rechargeable portable batteries.
The Batteries Act (BattG) requires manufacturers and importers to take back waste batteries as part of their extended producer responsibility. Collection schemes have been set up for the collection and handling of portable batteries that require manufacturers to properly recycle returned waste batteries and dispose of non-recyclable batteries.
The Chamber works with compliance companies to offer British exporters a simple and cost-effective solution to WEEE and battery compliance in Germany.