Due to Germany’s extensive Environmental Legislation, there are recycling obligations on manufacturers and distributors towards packaging, waste electronics and batteries.

© Fotolia / Cigdem

Fortunately, the Chamber offers British companies a practical consultancy service to explain your obligations under German Law and to simplify the application and reporting procedures to many of the schemes.

We 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.

Sales Packaging

The German Packaging Ordinance 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 (eg. cartons, cans, tubes, jars, pots, polystyrene moulds and chips, bubble wrap, plastic bags etc).

For all obligated companies, there is compulsory membership of a dual system (compliance scheme), which ensures that used sales packaging is regularly collected from private households and other locations throughout Germany.

For many years the German-British Chamber has for several years 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 obligation, please complete and return the form and we will be in touch. 

Recycling & Waste Management in Germany

Compliance Schemes for Sales Packaging

Companies must declare to their compliance scheme the weights of each material type for their sales packaging 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 produced, 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.

The German-British Chamber works with a number of compliance schemes in Germany and we can assist you in being compliant with the legislation.

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 many 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 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 will 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 the following volumes of packaging placed into the market are exceeded:
Glass › 80,000 kg/year
Paper, card, cardboard  › 50,000 kg/year
Other (Aluminium, plastic, compounds, tinplate)› 30,000 kg/year

As soon as these limits have been exceeded, a DOC must be submitted for all packaging materials. If the annual volumes are below these minimum volumes, the declaration of compliance is only required if requested by the local authority in Germany.

The data is submitted through the online portal 

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 and carbonated and non-carbonated soft drinks and alcoholic mixed drinks (eg alcopops).

Packaging for juices, milk and wine 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 Ordinance.

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 Batteries Act (BattG) in Germany aims to reduce the environmental impact of batteries and applies to all types of batteries and accumulators (also referred to as accumulators or 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.

For more information and advice, please email us the below form with details of your WEEE or battery sales in Germany.

Recycling & Waste Management in Germany