Packaging Producer Responsibility (EPR):

Obligations for manufacturers, distributors and online retailers.

Registration, return 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, responsibility and a wide range of obligations are transferred to the manufacturer and distributor (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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97234 Reichenberg – Germany
phone +49 931 4523070

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 support you in registering with LUCID, concluding a contract with a dual system, packaging licensing and submitting sales figures and annual volume 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 generated exclusively 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? Would you like to find out whether you are 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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Packaging FAQ

Your questions - our answers

Directive 94/62/EC of 20 December 1994 on packaging and packaging waste serves as the framework for the national implementation by the EU member states. The main objective of the Packaging Directive is to prevent and reduce the environmental impact of packaging waste and to ensure the functioning of the internal market. The Packaging Directive (94/62/EC) was last amended by Directive 2015/720/EU (OJ L 115, 6.5.2015, p. 11).

Producers, importers, distributors as well as online retailers of packaging who place batteries on the market for the first time on a professional basis. Basically any initial distributor is affected.
According to Packaging Directive 94/62/EC, a producer is any natural or legal person who places packaging on the market in any EU member state. This either can be the producer of the packaging itself, but also the reseller, irrespective of whether the reseller is established in the respective EU Member State or places on the market of that Member State from a third country. Those involved in the import of packaging and packaged products are also classified as producers.

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Directive 94/62/EC defines packaging as all products made of any materials of any nature to be used for the containment, protection, handling, delivery and presentation of goods. ‘Non-returnable’ items used for the same purposes shall also be considered to constitute packaging.

‘Packaging waste’ shall mean any packaging or packaging material covered by the definition of waste in Directive 2008/98/EC, excluding production residues

‘Packaging’ consists only of:

  • Sales packaging,
  • Grouped packaging or secondary packaging,
  • Transport packaging or tertiary packaging,
  • Despatch packaging or
  • Service packaging

We will also advise when participating in the dual system is mandatory.

Cf. Packaging FAQs>>>

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

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You already have to meet specific labelling requirements for your pakaging products in all EU Member States. In addition, we can advise you on your producer responsibility in all EU member states where you have to fulfill further obligations and support you on the registration and reporting process as well as any other administrative requirements.

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Documents and important legal bases