German Packaging Act in the UK: Obligations when shipping to Germany


With the Packaging Act (VerpackG), the German federal government passed a new law on January 1st, 2019 that regulates the disposal and recycling of packaging waste. For retailers in Great Britain who do business with German customers and send goods to Germany, some obligations have to be fulfilled. What do companies have to consider under the German Packaging Act in the UK? We have put together the most important information for you.

The Internet makes it possible: Many customers from Germany order from companies in Great Britain and have the products conveniently delivered by mail. On the marketplaces of Ebay, Amazon and Etsy, retailers from the UK often meet consumers who come from Germany, other European countries and from countries around the world. With the triumph of online trading, goods can now be shipped across national borders without any problems in a few days. The disadvantage, however, is obvious: A huge amount of packaging waste is created from shipping boxes, filling material and many other materials that have to be disposed of after a short, single use.

For this reason, the German federal government is countering this and has implemented the European Packaging Directive 94/62 / EC in German law in the form of the Packaging Act. The “VerpackG” is also the successor regulation to the German packaging ordinance. The aim of the new Packaging Act is, on the one hand, to create an incentive to forego packaging materials. On the other hand, the polluters of packaging waste should share in the costs of disposal and environmentally friendly recycling. This not only applies to distributors of goods from Germany and the European Union, but also to retailers from Great Britain.

Note: The first amendment to the German Packaging Act came into force on 3 July 2021. It provides for several new and stricter requirements for distributors of packaging. Among others, online retailers who use the services of fulfilment service providers and electronic marketplaces are affected by the changes. Find all relevant changes for online retailing at "Amendment of the German Packaging Act: regulations tightened for online marketplaces".

German Packaging Act in UK: Which retailers are affected?

The German Packaging Act affects UK retailers who, as distributors – including online retailers – bring packaging onto the market for the first time and send it to private end customers in Germany. Private end customers are private individuals, but also restaurants and public institutions such as schools, hospitals and barracks. Traders are affected from the first box that is shipped. If you fall under this description, you have some duties that you should strictly adhere to. In the worst case, there is a risk of fines of up to 200,000 euros. Packaging that has already been licensed does not need to be licensed again. However, for each packaging there must be solid evidence that the product has already been paid for. Anyone who sells B2B with companies in Germany is not affected by this rule. Instead, the return conditions for transport packaging in the B2B area apply here.

Please note: The German Packaging Act Amendment also affects B2B traders. Find out what has changed for B2B traders in our article "Amendment of the German Packaging Act: Changes in force since 3 July 2021".

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Step-by-step instructions: What are the specific obligations under the German Packaging Act for UK online retailers?

Affected traders in the UK react best to the German Packaging Act by following the following step-by-step instructions in order to meet their obligations:

  1. Traders in the UK must register in Germany with the Central Agency Packaging Register – the supervisory authority for the Packaging Act – via the LUCID database.
  2. Then they have to register in a dual system in Germany – this works conveniently and easily via Lizenzero, at the dual system Interseroh+ (the customer account at Lizenzero is also available in English).
  3. In the next step, the online retailer has to assess the material and volume of the packaging to be used for the current year and license it for a fee – from 39 euros plus VAT for small retailers with little packaging.

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  4. At the beginning of the following year, the exact volumes must then be reported to the dual system and the Central Agency Packaging Register.
  5. The retailer must submit a declaration of completeness to the Central Agency Packaging Register and the dual system – but only if the consumption of packaging materials is in the range of several tons.


Which packaging materials have to be licensed?

Basically, almost all packaging materials must be licensed. In the case of online retailers, secondary packaging such as shipping boxes and filling materials are likely to be particularly affected. Basically, however, almost every packaged product that is handed to the end customer in an outer packaging – for example in retail in a bag or in a wooden box – is affected. The list of materials includes the following substances:

  • Aluminum
  • Glass
  • Beverage carton packaging
  • Plastics
  • Cotton, wood, rubber, copper and ceramics
  • Paper, cardboard, cardboard
  • Other composite packaging
  • Ferrous metals


Sensitive penalties for violations of the German Packaging Act in UK

UK retailers can also be sanctioned if they violate the German Packaging Act. When sending unlicensed cardboard boxes to end users in Germany, the Central Agency Packaging Register can impose high fines, up to 200,000 euros – depending on the severity of the offense and the size of the company. In addition, competitors can also report companies that have not registered in the publicly accessible LUCID database to the Central Agency Packaging Register, which then initiates criminal proceedings.


Conclusion – German packaging law in the UK: Participation in the costs of environmentally friendly recycling

Not only retailers from Germany, but also from Great Britain, Europe and all over the world who sell their goods on the German market to end consumers, must meet the obligations of the Packaging Act of 2019, because packaging waste continues to be a big problem. Efficient and environmentally friendly recycling, in which many valuable materials are reused, is therefore essential. Registration with the Central Agency Packaging Register enables comprehensive monitoring of obligations and participation in a dual system secures the basis costs for waste disposal. The Packaging Act is therefore in everyone's interest, for a cleaner future with less packaging waste.

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