The German Packaging Act has been in force since 2019. With the aim of significantly increasing the recycling rates for packaging waste and therefore promoting a key driver for climate change mitigation, the Act requires manufacturers to purchase a paid licence for their sales packaging – i.e. all packaging that ultimately ends up with private consumers – from a dual system and therefore comply with their product responsibility obligations. The dual systems use the licence fees you pay to organise the collection, sorting and recycling of packaging waste. In addition, registration with the Central Agency Packaging Register Authority (ZSVR) and data reporting to the register is mandatory.

These requirements apply from the first packaging put into circulation and for all materials.

Do you ship to German costumers? Then you need to do the following:


German Packaging Act: Key points at a glance


License packaging with Lizenzero (and claim your 10% discount!) –
go here to enter your packaging volumes

✔ You’ll receive your system participation certificate.

Registration the LUCID Packaging Register run by the Central Agency Packaging Register.

✔ You’ll receive your LUCID registration number which you need to deposit in your BIBLIO Account.

Data reporting

Enter the volumes licensed and your dual system into the LUCID Packaging Register.

✔ You're done!

Licensing duty in fulfillment now always borne by commissioning distributor

Previously, fulfillment service providers have been required to license the shipping packaging that they fill in certain circumstances. According to the amended Act, this responsibility is now borne exclusively by the commissioning distributor from 1 July 2022.

More stringent checks by online marketplaces and fulfillment service providers

The amended VerpackG requires operators of online marketplaces and fulfillment service providers to conduct more stringent checks of their merchants. From 1 July 2022, online marketplaces may offer products from online merchants only if these retailers have complied with their VerpackG duties in full and are also able to provide proof of the same to the online marketplace. Similarly, fulfillment service providers are prohibited from offering services such as storage, packing or shipping for their merchants if no proof of compliance with the VerpackG duties is available.

What’s changed with the German Packaging Act amendment?

The amended VerpackG was published on 3 July 2021, around two years after the original Act. While the amendment does not alter the fundamental duties (as listed above) for distributors and producers, it has worked to close loopholes exploited by free riders.

For e-commerce, the following provisions in particular are important and both apply from 1 July 2022:

One licence package – many benefits

Lizenzero gives you a quick, straightforward way to license your packaging as required by the VerpackG. You can also benefit from our Peace of Mind Package: the extra services included free in your licence package are exclusive to Lizenzero, and make it easy for you to comply with the German Packaging Act while saving you time and trouble!

Due to the close partnership with BIBLIO, we can provide the best possible support for all queries regarding the requirements arising from the Packaging Act. Please don't hesitate to get in touch with us!


Packaging Law, licensing & registration
The most important questions at a glance

Which obligations do I have to fulfill according to the Packaging Law?

The Packaging Act imposes three obligations on sellers who ship packaged products to German end consumers:

  1. Licensing of your annual packaging volumes with a dual system (also called system participation). For this purpose, you can use Lizenzero, the online shop of the acknowledged dual system Interzero Recycling Alliance and preferred partner of BIBLIO: Enter volumes now
  2. Registration in the packaging register LUCID
  3. Data reporting to the packaging register LUCID (name of the dual system and licensed packaging volumes)
Why do I have to prove to BIBLIO that I fulfill my obligations with the German Packaging Act?

The Packaging Act was amended in July 2021. One of the changes in the law affects the operators of marketplaces such as BIBLIO: In order to create an additional control mechanism, they will have to check from July 2022 whether all traders who ship to Germany comply with the requirements of the Packaging Act.

If the merchant is unable to provide proof of compliance, a sales ban will take effect and the marketplace operators will have to restrict sales to Germany. Violations of this will be punished with high fines for the marketplaces.

What proof do I need to provide to BIBLIO?

You will need to present your LUCID-Number and confirm your system participation:

You willl receive your LUCID registration number (sometimes also called EPR number) after a successful registration in the LUCID packaging register.

Login to your BiblioDirect Seller Tools menu and click on the Account headline. Select Account settings from the drop-down. On the Business Info tab, you’ll see EU EPR compliance. Enter your LUCID-Number, check the box to confirm that you are registered with a dual system provider, and click save.

What is the difference between "license" and "register"?

The Packaging Act formulates a total of three obligations for merchants of packaging in Germany (also see question #1). These include the licensing obligation (also known as the system participation obligation) and the registration obligation.

Both obligations must be fulfilled at two different contact points:

  1. The licensing obligation refers to the fee-based participation of your packaging and must be carried out by you at a dual system such as Interzero Recycling Alliance (via Lizenzero). In return, Interzero Recycling Alliance takes over the disposal and recycling process of your packaging for you.
  2. The registration obligation, on the other hand, is carried out by you at the control authority Zentrale Stelle Verpackungsregister (LUCID).

The catalogue of obligations is completed by the data reporting obligation: This simply means that you enter the name of your dual system and your licensed packaging volumes in LUCID.

What applies to fulfilment and dropshipping?

Since the amendment, there is an obligation to monitor and new responsibilities for fulfilment service providers. If commissioning traders cannot provide evidence of system participation, they are not permitted to neither sales nor other activities (offering products, packaging, shipping, etc.) may be provided. In addition, the commissioning trader is responsible for licensing without exception, and in no case the fulfilment service provider.

The special feature of dropshipping is that the goods are packed directly by the sender and shipped to the end customer. Traders themselves therefore have no physical contact with the product or the packaging. The sender of the goods is therefore obliged in terms of the Packaging Act - both for the primary sales packaging and for the shipping packaging.

Attention: In the course of the amendment to the Packaging Act, online traders who use marketplaces must be able to present proof of licensing from 1 July 2022. This means that traders who use dropshipping and do not have a licensing obligation themselves also need to take action! You must request the registration number (EPR number) from your sender. When depositing the EPR number with the marketplace, you must take care not to pass it off as your own, but make it clear that it is the number of a third party.

Noch Fragen?
Nehmen Sie jetzt Kontakt mit uns auf.

Frau Annette Mustermann

Frau Annette Mustermann
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Please note: Due to the increased number of enquiries regarding the entry into force of the amendment on 01 July 2022, you may currently have to expect longer response times. However, you can be sure that your request will be answered.

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