Packaging Producer Responsibility (EPR):

Obligations for manufacturers, distributors and online retailers.

Registration, take-back and disposal of your packaging, compliance with the Packaging Directive, Packaging Act (VerpackG) for Germany. Dispose of packaging throughout Europe to protect the environment (recycling). We support you in distributing your products and packaging in compliance with the law.

DIRECTIVE 2006/66/EC - the legal framework for packaging and packaging waste in Europe It is impossible to imagine our daily lives without packaging. Everyone is familiar with packaged products, for example the transport and sales packaging from online mail order companies - packaging fulfills important functions for the product.

For this, extensive requirements and obligations must be observed, which are implemented, for example, via the EU Packaging Directive (2006/66/EC).

The Packaging Directive states that all EU member states with national regulations must adopt uniform rules for the handling of packaging, for example, to oblige manufacturers to assume product responsibility for the entire life cycle of the packaging. The Packaging Act, or VerpackG, transposes the European Framework Directive 2006/66/EC (amended by the Amending Directive (EU) 2018/851) into national law and defines the handling of packaging via "the placing on the market, the return and the high-quality recovery of packaging."

On the basis of this legal foundation, the polluter pays principle and product responsibility, among other things, the manufacturer and distributor are given responsibility and a wide range of obligations (EPR - Extended Producer Responsibility).

Packaging EPR - What am I obligated to do?

When is packaging subject to system participation?

The European Packaging Directive (Packaging Directive) regulates the placing on the market, return and high-quality recycling of packaging and is transposed into German law by the Packaging Act (VerpackG).
Packaging subject to system participation is sales packaging that is distributed commercially for the first time (distributors and retailers). The initial distributor is obliged to license the packaging and register it with the LUCID packaging register.

The law imposes product stewardship obligations on various legally defined actors, such as:

Distributors, (online) retailers and fulfillment service providers in the packaging and filling materials sector are also not exempt from the new obligations and are required to carry out checks.

In case of non-compliance, there is the threat of administrative offence proceedings and severe fines, e.g. in Germany of up to €100,000 for all actors who do not properly comply with the legal obligations.

Don’t miss out on your legal obligations in the respective EU countries and get in touch now to be informed about the obligations in the respective sales markets and to implement them safely.


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Types of packaging -

Types of packaging - what are the differences?

The Packaging Act in Germany, VerpackG for short, distinguishes between sales packaging, secondary packaging and transport packaging (see FAQ Packaging). The law defines sales packaging as service packaging that enables and supports the handover of goods to the end consumer and shipping packaging that enables or supports the shipment of goods to the end consumer. In terms of the VerpackG, outer packaging and transport packaging are also considered to be separate types of packaging, which must be correctly differentiated.

Our services -

License packaging and collect and dispose of old packaging (waste packaging) (recycling):

There are countless details to consider in order to correctly record the packaging obligation EU-wide and country-specific. Contact us already now to stay up to date on all the changes around packaging legislation.

We offer you:

Benefit from our Europe-wide and global networks and expertise.

Licensing packaging subject to system participation requirements

Anyone who fills packaging subject to system participation with goods for the first time and distributes it, e.g. makes it available on the German market, must license it (participation in a dual system) and carry out a registration in the German packaging register LUCID at the Stiftung Zentrale Stelle Verpackungsregister.

Dispose of sales / transport packaging -
Legally compliant and cost-efficient with ECOLOGICON.

Sales packaging

In accordance with the Packaging Act (as the national transposition of the Packaging Directive), packaging licensing is mandatory for both manufacturers and distributors when you place sales packaging on the market in Germany for the first time.
We will be happy to assist you in registering with LUCID, concluding a contract with a dual system, licensing packaging, and submitting sales figures and year-end quantity reports. This applies not only in Germany, but throughout the EU.

Transport packaging

This is packaging that facilitates the transport of goods to trade and protects them from damage in transit. Unlike sales packaging, transport packaging is only produced by commercial traders and is therefore not subject to system participation.
Nevertheless, this packaging is subject to some legal obligations that must be observed. We will be happy to advise you individually on the return and disposal of transport packaging that accumulates in the trade.

Packaging Consulting (VerpackG):

Do you need advice on identifying the packaging you place on the market? Want to know if they are considered a first distributor? You would like to be advised on the demarcation of distribution channels (private or commercial end user)?

We are happy to assist you with any obligations, measures and provide training to ensure you comply with laws and regulations.

Our network solutions for Europe - from a single source

National implementations of the Packaging Directive (Waste Packaging) lead to many differences in legislation and its implementation that need to be taken into account.
Do you export to other European countries? Whether for packaging, batteries or electrical appliances – we support you with our network solution in your sales countries (sales markets) so that you have the packaging directive under control and master it with flying colors.

If you are affected by these obligations, we can guide you through the implementation process by showing you step-by-step the requirements and helping you introduce necessary measures to comply with the laws and regulations.

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FAQ Packaging

Your questions - our answers

The handling of packaging is regulated by Directive 94/62/EC of the European Parliament and of the Council of 20 December 1994 on packaging and packaging waste. The main objective of the Packaging Directive is to prevent and reduce the environmental impact of packaging waste and, on the other hand, to ensure the functioning of the internal market. This packaging directive (94/62/EC) was last amended by Directive 2015/720/EU (OJ L 115, 6.5.2015, p. 11).

Manufacturers, importers and distributors as well as online mail order companies of packaging that place packaging on the market for the first time on a commercial basis. In this case, they are considered as so-called initial distributors.
The manufacturer according to the Packaging Directive (94/62/EC) is any natural or legal person who places packaging (packaged products) on the market in an EU member state. This can be the manufacturer of the packaging itself, but also the reseller, regardless of whether the reseller is established in the respective EU member state or distributes the packaging from a third country. A manufacturer is also a person who imports packaging and packaged products into the scope of this Act for the first time on a commercial basis.

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Directive 94/62/EC defines that packaging is a product made of any material and used for the containment, protection, handling, delivery and presentation of goods. All “disposables” used for the same purpose are also considered packaging.

Packaging waste is packaging or packaging materials that fall within the definition of waste as set out in Article 3 of Directive 2008/98/EC, with the exception of production residues.

In our FAQ you can find more information about when it is a

  • Sales packaging,
  • Repackaging,
  • Transport packaging,
  • Shipping packaging or
  • Service packaging deals

and when there is an obligation to participate in a dual system.

Cf. FAQs Packaging>>>

Packaging subject to system participation is explained in detail in the following video:

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In all countries of the EU, labeling of your packaging is already recommended, and in some cases you are already obliged to do so. In addition, we can advise you on producer responsibility in all EU member states where you have to fulfill further obligations and support and advise you on registration, notification, information requirements and all administrative steps.

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Documents and important legal bases