Packaging Act

What the Packaging Act covers

The German Packaging Act implements the European packaging directive and sets out who pays for collecting and recycling packaging. The underlying idea is simple: whoever puts packaging into circulation carries the cost of its disposal. That applies to manufacturers, to retailers and since 2022 explicitly to operators of online marketplaces.

For an online shop the decisive point is that the rule does not start with the product packaging. The shipping box, the filler material, the tape and the mailer bag are all packaging subject to system participation. Anyone who ships goods puts packaging into circulation, regardless of who produced it.

The three duties at a glance

• Registration: Every first distributor must register with the Central Agency Packaging Register and receives a LUCID registration number. It is a precondition for selling to private end customers and must be passed on to other retailers on request.
• System participation: The quantities actually put into circulation must be licensed with a dual system. Reporting is by material type and weight, not by unit count.
• Quantity reporting: The expected quantity is declared in advance, the actual quantity reported the following year. Anyone reporting fully through a dual system also fulfils the duty towards the Central Agency.

What changed in 2022

Until 2022 only commercial final distributors handing packaging to private end customers were covered. Since July 2022 the duty applies to all final distributors. For marketplaces this means they may no longer let retailers sell without a valid registration and must verify the numbers. Selling through a marketplace therefore does not bypass the check.

Common mistakes and costs

The most frequent mistake is calculating by unit count instead of weight. A shop with 20,000 orders at 300 grams of packaging each must report 6,000 kilograms, not 20,000 units. The second common mistake is counting orders instead of shipments, because partial shipments count more than once.

Costs consist of two parts: the licence fee to the dual system, tiered by material type and quantity, and the effort for reporting and documentation. For an average shipping box the licence fee sits in the cent range, which is why the amount looks small and is easily forgotten. A fine for missing registration is far higher, and competitors can have a missing registration challenged formally.

What it means in practice

Day to day it is a one-off setup plus two reporting dates per year. A fixed process helps: catalogue packaging types with weight and material, pull quantities from the shipping system, report in the same rhythm as accounting. Reducing packaging lowers licence costs, shipping weight and filler material at once, which also benefits the topic of sustainability.