08/09/2025

How-To-Guide: Packaging licensing in e-commerce – What do online retailers need to do?

Content:

 

Fast, easy, convenient—online shopping is becoming increasingly important to the general public. People are taking advantage of digital opportunities and ordering more and more online every year. An additional advantage is that consumers don't even have to leave their homes to receive their orders. Products are delivered right to their doorstep – with some providers, this now even happens on the day of ordering. However, in addition to the many advantages of online shopping for consumers and businesses, there is also a major disadvantage to the boom in shipping: it creates a huge pile of packaging waste from millions of additional boxes, shipping bags, and filling materials. Legislators are responding to the increasing amount of packaging waste with a new, stricter Packaging Act (VerpackG), which replaced the previous Packaging Ordinance on January 1, 2019. Since then, non-compliance can be quickly detected by the LUCID registration system of the control authority Zentrale Stelle Verpackungsregister (Central Agency Packaging Register): This can result in heavy penalties such as warnings, fines of up to EUR 200,000, or even sales bans.

In this blog post, we have therefore summarized the obligations that the Packaging Act entails for you as an online retailer. We also guide you through the licensing process with step-by-step instructions.

 

Which online retailers are affected by the Packaging Act?

Every company that uses sales packaging as a so-called initial commercial distributor for the first time and puts it into circulation must participate in a dual system. By paying a "license fee", the companies contribute to the professional collection, sorting and recycling of their packaging.

Affected are online retailers as well as all other companies that put sales packaging into circulation commercially for the first time. This therefore also includes sellers at all possible marketplaces such as eBay, Amazon or Etsy. Since the implementation of the Packaging Act is mandatory from the first packaging, even small online merchants must comply with the new Packaging Act.

Checklist: Am I affected?

  • Do you manufacture products that you then ship to German end customers?
  • Do you resell products that you purchase from other retailers/manufacturers?
  • Do you import products from abroad and resell them within Germany?
  • Are you not based in Germany yourself, but sell your products to end customers in Germany?
  • Do you use fulfillment service providers?


If you can answer “yes” to one or more of these questions, you are required to license your packaging in accordance with the VerpackG.

Quick check of packaging licensing for online retailers

  • The new, stricter Packaging Act came into force on January 1, 2019.
  • Online retailers must license sales packaging that they fill and put into circulation for the first time – before the first packaging is put into circulation.
  • Sales packaging includes shipping and product packaging including filling materials and packaging components.
  • This system participation takes place in a dual system like Interseroh+ (via its online store for packaging licensing Lizenzero).
  • Companies must also register with the Central Packaging Register Office in the LUCID database.

Calculate packaging volumes now

 

Packaging licensing for online retailers: What changes will the Packaging Act bring to e-commerce companies?

Basically, the Packaging Act does not change that much. Many of the regulations were already included in the Packaging Ordinance. The aim of the Packaging Act is to increase the quota of recycled packaging, to ensure fair competition and more transparency, and to be able to sanction violations of the new Packaging Act more strictly and more easily. Ultimately, the aim is to make a valuable contribution to the environment through more recycled packaging materials.

The greatest innovation of the law is the establishment of the Central Packaging Register office, which serves as a supervisory body for the Packaging Act. Companies have to register in the associated and publicly visible register LUCID (= registration obligation). This register can be viewed by customers and competitors and makes violations of the Packaging Act easily visible.

Those who have registered with LUCID can proceed to the next step. Subsequently, companies must license their packaging with a dual system (= system participation obligation). A packaging license for online retailers, for example, can be acquired very easily online via Lizenzero for the dual system Interzero.

Conclude now at favourable conditions

Finally, online traders must indicate the licensed packaging and the name of the dual system in their LUCID account (= data reporting obligation). This has to be done on a continuous basis, as the data provided by the dual system must always match the data in LUCID: So if an adjustment is made in one of the two places, it must be transferred identically to the other.

Please Note: The first amendment to the German Packaging Act has been effective since 03 July 2021. Online retailers who use the services of fulfilment service providers and electronic marketplaces are also affected by the changes. You can find all important information on the new requirements and transition periods in our blog post on the topic of the German Packaging Act amendment and the changes for online trade.

 

Instructions: How online retailers comply with the Packaging Act

The exact obligations of the VerpackG are listed below:

  1. Registration obligation: All companies concerned are obliged to register with the Central Packaging Register Office in the LUCID packaging register (a step-by-step guide can be found here: Registration at LUCID).
  2. System Participation Obligation: In order to contribute to the professional collection, sorting and recycling of packaging, initial commercial distributors must participate in a dual system such as Interseroh+ via the online store Lizenzero by licensing their sales packaging.
  3. Data reporting obligation: Finally, the licensed packaging volumes and the name of the dual system must be entered in the LUCID packaging register.

 

Packaging Act easily explained: 4 practical cases in e-commerce

1. Own online shop

As a store operator you ship the goods directly to the private end user? Since you fill the shipping packaging in this case with the ordered goods yourself and put them into circulation, you are under the obligation to implement the VerpackG specifications for the shipping packaging volumes.

In addition, you can be responsible for licensing the product packaging if you are also the manufacturer of the goods. Because in this case you also fill the product packaging with the goods, so that you are considered the initial commercial distributor of both forms of packaging and must therefore comply with the obligations for both.

2. Fulfilment service provider

New regulations of the German Packaging Act Amendment: The German Packaging Act Amendment, which came into force on 3 July 2021, changes the responsibility for packaging licensing in fulfilment. From 01 July 2022, fulfilment service providers are no longer obliged to license shipping packaging. The licensing obligation then falls under the responsibility of the commissioning retailers. In addition, fulfilment service providers must check from 1 July 2022 whether their commissioning retailers have fulfilled their system participation obligation.

As soon as you are the manufacturer or initial filler of the product packaging, you must fulfil the obligations of the VerpackG for the product packaging.

3. Dropshipping

Since you as the seller of the goods in the case of dropshipping have no physical contact at any time with any of the packaging put into circulation, since the goods are shipped directly by the producer or wholesaler, you do not need to license either the product or the shipping packaging.

Exception: If you as a retailer can be recognized on the outside of the shipping packaging alone, you must comply with the obligations for this. However, as soon as a shipping service provider is recognizable with you, alone or none of you, the above mentioned explanations apply.

4. Import of goods to Germany

You are not located in Germany but you sell products to German private customers? Since the Packaging Act applies to all sales packaging that is put into circulation in the German market, you are also affected by the law.

Basically it can be said that always the company must comply with the obligations of the VerpackG, which is responsible for the goods when they cross the border. All imported packaging is then subject to this obligation. Even if this is usually the importer, we recommend that this be recorded in a contract with the partners to eliminate all doubts.

 

Legal warnings for online merchants: What penalties are threatened by disregarding the licensing obligation?

As mentioned at the beginning, one of the biggest innovations of the Packaging Act is the transparency created by the Central Packaging Register Office with its packaging register LUCID. Customers, competitors and competition centers can now easily see which online traders have registered. This is to create fair competition.

If an online trader does not behave according to the rules, he can be warned. In addition, the new Packaging Act will result in some considerable penalties for mail order companies in the form of fines and bans on sales. A violation of the law counts as an administrative offence and can be punished with a fine of up to 200,000 euros per case according to §34 VerpackG. Online traders and all tradespeople who bring sales packaging into circulation should therefore be absolutely sure to observe their obligations.

 

Online traders can meet their obligations without much effort

What looks like a lot of work at first glance can be done in a few minutes in practice. Registration with the Central Packaging Register Office can be carried out online in just a few steps, free of charge and in compliance with the law. And the subsequent licensing of packaging volumes in a dual system can also be done conveniently on the Internet. With Lizenzero, online retailers can create a customer account in just a few steps, determine their packaging volumes including the associated license fee without obligation using a calculation assistant and calculator, and thus conveniently implement their System Participation Obligation.

This way, companies can quickly and easily make a contribution to recycling and the environment – and have more time to concentrate on their business and their customers.

 

Packaging Act amendment: is everything different now?

The amendment, which came into force on July 3, 2021, has brought about a number of changes and additions to the Packaging Act. The following are particularly important for you as online retailers:

Control obligation for electronic marketplaces (e.g., Amazon, eBay, Etsy)
Since July 1, 2022, operators of electronic marketplaces have had a control obligation with regard to the Packaging Act. Specifically, this means that marketplaces will in future check whether retailers who sell their products to German end consumers are complying with their registration and system participation obligations. If they cannot provide the relevant evidence, a sales ban will apply.

Control obligations and new responsibilities for fulfillment service providers
Even if you use fulfillment services for shipping your goods, new obligations apply, as fulfillment service providers have also been subject to control requirements since July 1, 2022. As the commissioning retailer, you must also provide proof of licensing for your packaging and registration in the LUCID packaging register if you sell goods to German end consumers. If you do not have this proof, fulfillment service providers are not allowed to perform services such as storage, packaging, or shipping for you. In addition, you as a retailer are now responsible for licensing the shipping packaging without exception, and no longer the fulfillment service providers, as was previously possible in individual cases.

What does the term EPR mean and what does it mean for online retailers?

EPR stands for Extended Producer Responsibility. It is based on the principle of product responsibility, which retailers and manufacturers must fulfill for their products. Important to know: Not only the product itself, but also all packaging and (product) components that are put into circulation and disposed of by end consumers are covered by EPR. The requirements for packaging are explained in detail in this article. In addition to packaging, this extended producer responsibility must also be fulfilled in Germany for electrical appliances (WEEE) and batteries.

Similar to the Packaging Act, there have also been adjustments to the legal texts for batteries (BattG) and electrical appliances (ElektroG). The control obligations that have already applied to packaging on marketplaces since July 2022 have been extended to batteries and electrical appliances since January 2023. Online retailers must also be able to provide appropriate EPR evidence for these goods. There are separate registration and participation procedures for batteries and electrical appliances. More information on the requirements for batteries and WEEE can be found here.

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License packaging and restore peatlands

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