Packaging Act
The Packaging Act (VerpackG, in force since 1 January 2019, replacing the former Packaging Ordinance) is the central German framework for placing packaging on the market and take-back and recycling obligations.
Who is affected:
- Manufacturers and importers who first place filled packaging on the German market commercially
- Also online retailers and foreign direct suppliers with German end consumers
Obligations under VerpackG:
1. Registration in the LUCID packaging register (operated by: Stiftung Zentrale Stelle Verpackungsregister)
2. System participation: participation in a dual system (e.g. Der Gruene Punkt, Interseroh) and payment of a licensing fee
3. Completeness declaration: large placers-on-market must annually report audited quantities
Relevance for glove manufacturers/importers:
- Cardboard packaging, film packaging, and dispenser boxes for gloves require licensing
- Violations risk fines and cease-and-desist letters
- The VerpackG applies only to the German market
Similar regulations apply in other EU countries (Austrian Packaging Act, French REP system etc.), based on EU Packaging Directive 94/62/EC.
Frequently asked questions
Who must register under the German Packaging Act?
Anyone who first places filled packaging on the German market commercially - i.e. manufacturers, importers, and online retailers, even if based abroad and delivering directly to German end consumers.
What are the consequences of non-compliance with the Packaging Act?
Unregistered companies commit an administrative offence and risk fines of up to EUR 200,000. They can also be subject to cease-and-desist letters from competitors. LUCID registration is mandatory before first placing on the market.