Do you or your business sell physical products to consumers in Germany? If so, you need to comply with the new German packaging laws introduced in January 2019. Don’t worry; it could be more straightforward than you think. I went through the whole process in a little under 2 hours. Let’s dive right in:
What is the new German packaging law?
Germany is keen to lead the world in recycling and in reducing their waste footprint. This new law is meant to enforce a stricter policy on packaging producers who sell their goods in Germany. The law is known as VerpackG (it replaces the previous law known as VerpackV) and sets out the obligations of packaging producers. The law is also referred to as the "dual system" and separates the responsibilities in two distinct conditions:
Who is required to comply?
Basically any business who sells or distributes products to end consumers in the German market. If you have an online store or sell via online marketplaces such as Amazon into Germany, you definitely need to take action. The law includes suppliers of packaging materials, packaging converters, pack/fillers, retailers, importers and distributors.
What if I simply ignore it?
Any company who fails to comply with the new regulations is liable for a fine of up to €200,000 Euro as well as potential trade sanctions. If you’re a small company, the risk of direct prosecution by the German state may be fairly small. However, what COULD happen is that your direct competitor checks the public database, finds your brands are not registered, and reports you to the authorities. OR one of your customers decides to check if you’re in the database and can’t find you. This could lead to potential serious problems for your company (and your competitors taking all your customers).
So how do I comply?
Just follow these easy steps:
Then, once this is completed you can go back to LUCID and provide your contracted waste disposal, they run a cross-check, and if all is well, you have registered for the dual system packaging law in Germany.
I hope this has been helpful.
Please leave any comments and questions below.
Q: Should I also declare the Amazon packaging (ie the box or wrapper that amazon puts on my product before shipping out)?
A: No, Amazon has to declare their own packaging waste to the German authorities.
Q: If we sell other brand's products who is liable for the product packaging?
A: This law applies to all manufacturers and/or retailers who “are the first” to sell a packaged product – regardless of whether large or small – to the customer directly at the counter in a walk-in retail business or online to the end customer. So if you sell it to the end-consumer, you have to declare it.
Q: Where can I look up the formal guidelines?
A: Click here for the link to the formal guidelines from LUCID, which includes an English-language FAQ file
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