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Your path to legally compliant licensing
Sales packaging in its diversity holds great potential for being returned to the material cycle through recycling. The German Packaging Act (VerpackG), which replaced the German Packaging Ordinance (VerpackV) in 2019, also provides for this material recycling for the vast majority of sales packaging. Manufacturers and other distributors (or dealers) are obliged to participate in a dual system for their sales packaging - commonly known as "sales packaging licensing" or "packaging licensing".
Registration and data reporting at LUCID
The Central Packaging Register (ZSVR) was introduced by the German Packaging Act (VerpackG). Its purpose is to check whether the requirements of the Packaging Act are being complied with. Manufacturers, traders and online retailers who place packaging for private end use on the German market must:
Estimate the volume of packaging they will place on the German market in a given year and submit these planned volume to a dual system in Germany such as the GreenDot,
3. Report data
Also report their data regarding the volumes reported to one or more dual systems to the ZSVR in the same way.
4. Share registration number
The LUCID registration number is communicated by manufacturers, distributors and online retailers to their dual system so that the data reconciliation works.
Sales packaging
Packaging can take a wide variety of forms and be made of a wide variety of materials. The German Packaging Act contains comprehensive regulations and definitions for the different types of packaging. The Packaging Act does not recognize any trivial limits: Those affected must already become active from the first packaging placed on the market and take care of the licensing of their packaging. GreenDot provides information here on the various types of packaging that are subject to system participation.
Product packaging
Product packaging directly surrounds the goods. They perform important functions such as product protection and product information, and in many cases they also support the shelf life of a product. Examples include the yogurt pot, the toothpaste tube, the vegetable jar, the wine or ketchup bottle, cosmetics and care products, but also the honey jar from the beekeeper. Product packaging is part of the packaging that is subject to system participation and must be licensed with a dual system such as the GreenDot.
Outer packaging
Outer packaging is additional packaging that wraps product packaging. For example, as a film around beverage cans and the bottle six-pack or as a cardboard tray, they reinforce the protection of the goods and facilitate transport for the buyer. Offered for sale as a complete sales unit, outer packaging must also be licensed with a dual system such as the GreenDot in accordance with the Packaging Act.
Service packaging
Service packaging is only filled when a product is purchased in the store. The carrier bag is just as much service packaging as roll bags, floral paper, pizza boxes, disposable tableware, to-go cups, etc. A packaging license must also be concluded with a dual system such as the GreenDot in order to place service packaging on the market.
Important to know:
The system participation obligation can be handed over to the pre-distributor of the service packaging.
If this is the case, the final distributor of the service packaging, i.e. the person who fills it and hands it over to end consumers, should have this confirmed. This is because the final distributor must, as of
July 1st, 2022, the final distributor must register in the LUCID register of the Central Packaging Register. This also applies if the previous distributor of the service packaging has already taken over its licensing.
Shipping packaging
This topic is particularly important for operators of online stores. Packaging in which goods are shipped to private end consumers in Germany counts as packaging subject to system participation. This means that they must be involved in a collection, recovery and recycling system such as the GreenDot. This applies to both sales and outer packaging as well as shipping packaging, e.g.
shipping bags with or without air cushioning,
other envelopes,
shipping cartons,
Filling material such as polystyrene chips,
cushioning cardboard or air bubble packs,
tissue paper,
stretch films,
air bubble films,
foam foils,
parcel tape,
delivery bags,
strapping tapes or
corrugated cardboard.
For online retailers or online retailers on electronic marketplaces, GreenDot has prepared further important information in the find-out tool, e.g. on the question of what must be observed under the Packaging Act from July 1st, 2022.
The German Packaging Act
If I, as a manufacturer, distributor or online retailer, sell commercially to private end consumers, fill packaging for the first time (including shipping or service packaging subject to system participation) and place it on the market in Germany, I am considered a "manufacturer" under the German Packaging Act and am therefore obliged to participate in a dual system, such as GreenDot, for the packaging. The same applies if I import goods from abroad for resale in Germany. The German Packaging Act has far-reaching implications for manufacturers, distributors and online retailers. It is mandatory, for example, if the online retailer packages its goods itself or imports packaged goods and sells them to private end consumers via electronic marketplaces in Germany. In this case, both the actual packaging of the products themselves and the additional shipping packaging used, such as cardboard boxes or plastic bags including filling material, are subject to the provisions of the Packaging Act.
The German Packaging Act (VerpackG)
On January 1st, 2019, the Packaging Act (VerpackG) replaced the Packaging Ordinance (VerpackV). The obligation to participate in a system such as GreenDot remains, but some new regulations and obligations have been added.
We have summarised the most important information here in an easy-to-understand manner.
Participate in our dual system in order to fulfill your obligations from the new German Packaging Act 2019. In addition, the trademark utilization contract allows you to label your sales packaging with the well-known trademark GreenDot. Since 1990 GreenDot has been symbolizing producers´ responsibility. Our user-friendly online service makes it easy for you to manage all data concerning your packaging license. Save time by accessing everything you need for licensing your sales packaging and declaring your packaging amounts online!
Legally compliant participation in the dual system
With the packaging license, you are participating in the dual system of GreenDot, the prestigious and most experienced provider in Germany.
Access to the user-friendly online service
You will be given access to our practical reporting scheme, under which you can process all the formalities involved in your packaging license with time-saving efficiency.
Using the GreenDot trademark
By concluding our trademark usage agreement, you obtain the right to use the internationally recognised GreenDot trademark.
Disposal service for packaging
We will be pleased to provide you with transparent advice on our comprehensive recycling solutions, and will gladly submit the appropriate non-binding quotations.
What is sales packaging?
Sales packaging is typically offered to private end consumers filled with goods. Private end consumption includes not only private households, but also hotels, restaurants and other catering establishments, hospitals, educational institutions and freelancers, as well as some craft businesses, agricultural enterprises and numerous other institutions.
Is my packaging subject to system participation?
The Central Packaging Registry (ZSVR), which was set up in the Packaging Act, has published a system participation requirement catalogue, which shows which packaging the ZSVR considers to be subject to system participation. If you cannot find your packaging in the catalogue, you can submit a corresponding application for classification to the ZSVR.
How does packaging licensing work?
It's quite simple and is essentially done in three steps:
Obligation to register with the ZSVR
Anyone affected by the German Packaging Act must register their company data with the Central Packaging Register Office (ZSVR) in the LUCID database, which is partially open to the public.
System participation in a dual system
According to this, manufacturers, distributors or online retailers must participate in a German dual system such as the GreenDot for those packaging volumes that they expect to place on the German market in a year. To do so, they must report the registration number assigned to them by LUCID to their dual system. This enables the ZSVR to exchange and reconcile information between the data provided by the obligated party and the assigned dual system.
Enter the expected annual quantity per material and have the annual fee calculated,
enter company data,
select payment method and conclude contract.
Data reporting to LUCID
If manufacturers, distributors or online retailers have concluded a participation agreement with a German dual system, e.g. the GreenDot, they must regularly enter in LUCID both the name of the dual system and the quantity reported there.
This applies in particular to the year-end report: At the beginning of the following year manufacturers, distributors and online retailers have to submit a volume report on the packaging volumes actually put into circulation to their dual system and store the same information in the LUCID database. With the dual system GreenDot, this year-end report can be completed online in just a few steps.
Are you still unsure?
Which category do you fall into and what do you actually need to register? Don't worry, we'll help you.
You export your products to other EU countries? Then you should know the respective guidelines for packaging licensing. We are one of the founders of PRO Europe umbrella organization where systems of collection and recovering packages have joined forces to support producers in fullfilling national legal requirements. They will be pleased to provide advice and practical assistance.