Below is a list of commonly asked questions. Use the keyword search to jump quickly and easily to the right answer.

1. How does the German ‘Dual System’ work?

In addition to the bin for residual waste, there is also another collection system, especially for sales packaging waste. This is known as ‘Dual System’. Packaging manufacturers and distributors pay for this system. Rules about the system are set out in the German Packaging Act (VerpackG).

The Dual System organises the collection, sorting and recycling of packaging waste. This waste is created by consumers buying packaged goods and then disposing of the packaging as waste. If you market this packaging as a manufacturer or a distributor, you must take part in the Dual System. This is also known as ‘licensing’ your packaging. By paying your licence fee for your packaging, you and all other packaging companies involved are helping to pay for the Dual System. You also fulfil your product responsibility, because used packaging can then be disposed of and recycled at no cost to the consumer. This is also required by the VerpackG.

So who is responsible for checking that companies are licensing their packaging with a one of the existing dual system companies as required? The German Packaging Act has created a new authority to carry out this work, called the ‘Central Agency Packaging Register’. The Agency has to create a public (!), list of all registered companies on the Internet and to monitor compliance with the law. The aim is to ensure transparency, common standards and fairness in the market – and to make sure that all companies affected participate in environmentally-friendly recycling.

All distributors of packaging must register with the Central Agency by 1 January 2019. Distributors must also count and report their annual packaging volumes to the Agency and to their dual system.

2. Who organises the Dual System?

Several private companies in Germany are officially responsible for organising the Dual System nationwide. These companies are also known as ‘dual systems’. They make sure that packaging is collected and recycled as required by the Packaging Act. The fee you pay for the packaging licensing covers the costs for delivering and emptying collection bins like the ‘yellow bin’. The fee also covers sorting costs and other charges that are paid to local authorities for public relations work and waste management consulting services.

For small businesses, especially online shops, it is important to be able to count on a reliable partner for packaging licensing. With its many years of experience, the dual system of Interseroh (Duales System Interseroh, DSI) ensures that you fulfil all legal obligations under the Packaging Act cost-efficiently.

 

3. What happens to the packaging after it has been separated and disposed of by consumers?

When you place packaging on the market as a retailer, you are also responsible for your product. You are therefore required by law to take part in a dual system. This is the only way to ensure that recycling and environmental protection work properly.

In the example of a perfect recycling chain, sales packaging is first collected separately according to the type of material: packaging made from plastic, composites, aluminium, ferrous metals and other materials is collected in the ‘yellow bin’ or ‘yellow bag’. Paper and cardboard packaging should be collected in the paper bin or paper container, while glass packaging is sorted by colour and thrown into the ‘bottle banks’.

In the next step, the yellow bins and yellow bags are taken to sorting plants. Here, they are emptied and the waste is sorted into material types before being sent to a processing plant. The German Packaging Act sets targets for this recycling. According to the Act, these recycling targets will be increased in two stages by 2022:

MaterialTarget nowTarget from 2019Target from 2022
Glass 75 % 80 % 90 %
Paperboard, paper and cardboard 70 % 85 % 90 %
Ferrous metals 70 % 80 % 90 %
Aluminium 60 % 80 % 90 %
Beverage cartons 60 % 75 % 80 %
Other composite packaging 60 % 55 % 70 %
Plastics (mechanical recycling) 36 % 58,5 % 63 %

At the moment, the recycling target for plastics set by the German Packaging Ordinance is 36 per cent. The new Packaging Act will first raise this target to 58.5 per cent from 2019 onwards. From 2022 onwards, the recycling target for plastics will be 63 per cent.

4. What do I have to do to comply with the German Packaging Act?

If your used packaging is normally disposed of by consumers who have bought your products directly or ordered them, then you must register with the Central Agency Packaging Register and also take part in a dual system (see question 7).

Signing an agreement with Interseroh’s dual system (Duales System Interseroh, DSI) agreement is an easy and simple way to make sure that you comply with the German Packaging Act. To confirm and prove that you are taking part in the DSI, you are given a certificate that you can show to local authorities and distribution partners. Do you operate an online shop?

If so, you can also use an online quality seal in your shop that clearly shows you are taking part in Interseroh’s dual system.

 

5. Who has to license packaging?

To comply with German legislation, every manufacturer and every dealer who sells any kinds of packaged goods to consumers must take part in a dual system and apply for a packaging licence. The German Packaging Act (VerpackG) generally applies to everyone who fills packaging with goods and places these goods on the market in a sales unit. This is why manufacturers and distributors of packaged products are also known as ‘initial distributors’.

This applies whether you are a manufacturing company producing your goods ‘offline’ or someone who is running an online shop. The VerpackG also applies to merchants who sell their products using platforms like Amazon, eBay and etsy. In this case, ‘licensing’ means that you use an official dual system to report the packaging volumes used in selling your products (this requires payment of a fee).

Apart from sales and mail-order packaging, the German Packaging Act also applies to the ‘service packaging’ used by retailers such as bakers (for example). Since there is no minimum volume, a company must take part in a dual system as soon as it distributes one packaged product. The obligation therefore also applies to sole traders.

 

6. Is there a minimum volume rule for licensing packaging?

No – the German Packaging Act (VerpackG) applies to anyone who ‘places packaging on the market’. The actual volume of packaging you place on the market is not important. As soon as you ship packaging that contains goods, the law requires you to register with a dual system. This means that there are no exceptions. Even sole traders or very small-scale manufacturers must license their packaging. For e-commerce, this affects sole traders who sell goods on platforms such as eBay, Amazon or etsy, for example. In traditional retail, the obligation also applies to beekeepers, wine growers and bakers, for example.

With Interseroh’s dual system (Duales System Interseroh, DSI), you can license your packaging starting from EUR 39 a year.
Apply for your licence now.

7. What is the most convenient and cost-effective way for me to comply with the German Packaging Act?

Simply take these steps to ensure you meet the requirements of the German Packaging Act:

  • Use Interseroh’s dual system to license the types and volumes of packaging that you place on the market in Germany. You can enter your data here.
  • Register with the Central Agency Packaging Register at www.verpackungsregister.org/en/ : you do this by entering the volumes that you have reported to us into the Agency’s ‘LUCID’ database (the volumes reported to the Central Agency and to Interseroh’s dual system must be identical). See question 8.
  • You then enter the registration number you received from the Central Agency during the registration process in your Lizenzero customer account.

Ideally, you should report your packaging for each calendar year at the beginning of each year. To do this, you first make an estimate of the volumes involved: the annual licence fee will depend on the type and total weight of your packaging. If necessary, you can adjust your volumes in your customer area at any time during the year.

Once a year – usually at the start of the next year – you then report the actual volumes of packaging and material you placed on the market for the previous licensing year. This report – called the ‘end-of-year volume report’ – must be sent to the Central Agency and to your dual system provider. Lizenzero guides you through the entire packaging licensing process in just a few clicks.

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8. How do I register my packaging with the Central Agency?

Step 1: To register with the Central Agency Packaging Register, the first step is to provide the Agency with the following information:

  • The name of your company, plus address and contact details,
  • an authorised representative (must be a natural person),
  • your German or European VAT registration number,
  • all brand names that you use to place packaging that requires licensing on the market,
  • a declaration that you are fulfilling the law on take-back obligations by taking part in a dual system,
  • a declaration that all information given is true.

Step 2: When registering, you will receive a registration number. You enter this number and the packaging volumes to be licensed when you open an account with a dual system (Lizenzero lets you open an account without the number, but you should provide this number as soon as possible afterwards; see question 10). Please note: All registration numbers issued before 1 January 2019 are temporary numbers. When the German Packaging Act becomes law, the Central Agency will automatically send you your final registration number. You must also submit this number to your dual system provider.

Step 3: You now provide the Central Agency with the following data:

  • Material type and volume for the packaging to be licensed
  • Name of the dual system
  • Period of participation in this dual system

If you change your packaging volumes during the year or if other relevant details change (such as your company name or place of business, tax ID, contact details), you must inform the Central Agency and your dual system provider about these changes without delay.

For the full list of requirements of the Central Agency, please visit Central Agency Packaging Register .

9. What is the task of the Central Agency Packaging Register?

The German Packaging Act sets up the Central Agency to ensure transparency and fair play in relation to packaging licensing. The Agency is a central hub for the data from all different dual systems. The Agency itself reports to the Federal Environmental Agency. All companies whose packaging is typically disposed of by final consumers must take part in a dual system. From 2019 onwards, they must also register with the Central Agency.

During registration, each company receives an individual registration number. This number must be used when opening an account with a dual system – such as Interseroh’s dual system.

Details of all registered companies are kept in a publicly accessible register by the Central Agency. In addition, the Central Agency also records the packaging volumes reported by manufacturers, distributors and the dual systems. The Central Agency then compares the volumes reported by each of these groups to ensure that they match up.

 

10. Can I take part in a dual system if I do not have a registration number?

Yes. You can sign a licence agreement with Lizenzero for Interseroh’s dual system (Duales System Interseroh, DSI) and open your customer account even without a registration number. This does not complete the process, however, and you are not yet legally compliant. In this case, you should provide your registration number as soon as possible.

11. When do I have to license my packaging?

Ideally, you should report your packaging for each calendar year at the beginning of each year. You report your packaging by making an estimate of the volumes you plan to make or distribute. The calculation of your annual licence fee is based on the type and total weight of your packaging.

Once a year – usually at the start of the next year – you then report the actual volumes of packaging and material you placed on the market for the previous licensing year. This report – called the ‘end-of-year volume report’ – must be sent to the Central Agency and to your dual system provider.

If you change your packaging volumes during the year or if other relevant details change (such as your company name or place of business, tax ID, contact details), you must tell the Central Agency and your dual system provider about these changes without delay.

Lizenzero guides you through the entire packaging licensing process in just a few clicks, and also reminds you to send in your end-of-year volume report every year.

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12. What are the penalties if I do not comply with the rules and regulations of the new German Packaging Act?

According to Section 7(1) of the German Packaging Act, all companies who place packaged goods on the market for consumers must report this packaging to a dual system. If you do not license your packaging or report the wrong volumes, you are breaking the law and can expect to a pay a fine – which may be up to EUR 200,000. Competitors can also report other companies for breaking the law. Thanks to the level of transparency now created by the Central Agency, it is easy to see which companies have licensed their packaging and which have not. This enables businesses in the market to check that other competitors are playing by the rules.

13. Are there also rules for a minimum volume in the German Packaging Act?

No. There is no minimum packaging volume. Manufacturers and distributors must licence all packaging – from the very first piece of packaging placed on the market. There is a limit only for very large volumes. If your packaging goes over this limit, you must complete a Declaration of Compliance, and report your volumes to the Central Agency and your dual system. This Declaration must be confirmed by an authorised third party and sent to the Central Agency. The review and confirmation of the Declaration can be made by a registered expert, auditor, tax advisor or certified public accountant. In most cases, however, small/sole traders are not affected by this particular regulation.

The minimum packaging volumes per year for the Declaration of Compliance are as follows:

MaterialMinimum volume
Glass ab 80.000 kg
Paperboard, paper and cardboard ab 50.000 kg
Plastic, metal, composites (in total) ab 30.000 kg
14. How can I calculate the packaging volume I need to license?

You can calculate the packaging volume to be licensed in four steps:

a) Identify the types of material used in the packaging of each product,
b) calculate the weight of the individual types of material,
c) estimate the sales figures for your products,
d) multiply the estimated quantities of products sold by the weight calculated for each type of material.

Please remember that an independent auditor must be able to check the process you have used to estimate your packaging volumes.

We can help you to calculate your packaging volumes. Our Calculation Assistant can be found here.

15. What packaging materials do I have to license?

All types of packaging that are normally disposed of by final consumers have to be licensed. The following categories of packaging materials are used:

Packaging materialExamples
Paperboard, paper and cardboard Shipping cartons, filling material
Plastics Padded envelopes, parcel tape, bubble wrap
Glass Bottles, jars
Aluminium and other metals Tubes of cream, chocolate wrappers
Ferrous metals Cans
Composite beverage cartons Tetra Paks
Other materials Cotton, wood, rubber, cork, ceramics
Other composite packaging Blister packs, vacuum packaging

Please remember that an independent auditor must be able to check the process you have used to estimate your packaging volumes.

We can help you to calculate your packaging volumes. Our Calculation Assistant can be found here.

16. What types of packaging do I need to license?

It is really quite simple: when looking at a particular type of packaging, it is important to identify where it is ‘normally’ disposed of. According to the German Packaging Act, you must take part in a dual system if your products are typically sold or shipped to consumers and the product packaging is then disposed of for collection. This kind of packaging is known as ‘sales packaging’. Sales packaging also includes service packaging (used to wrap goods in-store) and mail-order packaging (used to ship goods).

Apart from sales packaging, another type is ‘transport packaging’ – such as pallets – which is used for the safe and simple transportation of goods and products. Note the difference: this is not disposed of by consumers but by the packaging distributor (in retail, for example – see question 18).

Service packaging

Service packaging is a special type of sales packaging: the difference is that service packaging is only filled with goods when it is handed to the consumer. Service packaging is often used in restaurants or the food service industry for selling food and drink in bakery bags, coffee-to-go cups, pizza boxes, aluminium trays, disposable tableware and carrier bags. Many other service providers also use service packaging such as fruit baskets, trays, carrier bags or dry-cleaning suit bags when handing their goods to customers. However: According to the German Packaging Act, service packaging must also be licensed with a dual system (see question 17).

Mail-order packaging

Mail-order packaging is another special type of sales packaging. This type of packaging is used directly or indirectly to ship goods to consumers and is usually filled by the last distributor in the chain. After the German Packaging Act, mail-order packaging like shipping cartons or filling material is treated like ‘normal’ sales packaging. This packaging must therefore be licensed in a dual system and registered with the Central Agency. The German Packaging Act does not allow the purchase of mail-order packaging that is ‘pre-licensed’ – which is therefore not permitted.

 

17. Are there any kinds of sales packaging that do not have to be licensed?

According to the German Packaging Act, you must license all of your sales packaging that is normally disposed of by consumers.

There are exceptions only for some kinds of service packaging. According to the Act (section 7(2) of the VerpackG), if the last distributor in the chain is the first to place (filled) service packaging on the market, they can require the other distributors in the chain to license the unfilled service packaging that they are supplying. What is new: the last distributor in the chain can now demand proof of licensing.

This exception does not apply to mail-order packaging.

 

18. Who organises waste disposal for transport packaging?

Transport packaging is the packaging that you use to transport goods to another merchant or manufacturer. This packaging is not disposed of by consumers and so it is not licensed in a dual system. Accordingly, there are special rules for the taking back and recycling of transport packaging. According to the German Packaging Act, anyone placing transport packaging on the market has a product responsibility and has to make sure that the packaging is professionally recycled. Interseroh also offers services for the professional and environmentally friendly taking back and recycling of this packaging.

Contact us for details of our transport packaging recycling services

19. What about sales packaging that will be used for export?

The German Packaging Act does not apply to sales packaging that is used for export. Accordingly, this packaging does not need to be licensed in a dual system. However, as a manufacturer and distributor, you must make absolutely sure that this export packaging will not be placed on the market in Germany. According to the German Packaging Act, the packaging design or relevant shipping documents must confirm that the affected packaging is for export only. This applies as soon as the packaging is placed on the market (for export). If this packaging is provided to consumers later – and therefore has to comply with the regulations of the German Packaging Act –it then has to be properly licensed in a dual system as soon as possible.

20. Can I re-use old packaging provided by my supplier?

Yes, but not without licensing.

The packaging you received from your supplier, from a private source or by any other means is often undamaged – and much too valuable to simply dispose it of. However: If you decide to re-use this packaging to sell your goods to consumers, then you are obliged to license this packaging in a dual system. This is because this packaging becomes shipping or sales packaging once you fill it with your goods.

In this case, we recommend licensing all of such re-used packaging yourself to ensure that you comply in full with the German Packaging Act.

 

21. Do I need to apply for a packaging licence if I am shipping the product in the original packaging to a third party?

No. If you are a product dealer and are simply shipping the product to the consumer without any extra packaging – in the manufacturer’s original carton without a shipping box – then you do not need to apply for a packaging licence.

However, you may be asked to provide proof that you are not using extra packaging. Accordingly, you must keep records that show that the product packaging has already been licensed by your supplier/manufacturer. In addition, you should also check that the manufacturer is properly registered with the Central Agency Packaging Register. Alternatively, you can ask your supplier to provide you with a document that proves that there is a valid packaging licence for the product in its original packaging.

 

 

22. What are my responsibilities if I am a drop shipper?

Drop shipping is a growth market due to the online shopping boom. Instead of shipping the products themselves, operators of online shops may decide to distribute their products by using popular online marketplaces such as Amazon and eBay.

With drop shipping, this online marketplace is used to ship out the goods to the consumer. Although the goods are sent ‘by’ the online shop, the shop actually has no physical contact with the product.

You only need to apply for a licence if you a) manufacture the goods sent from your shop by the marketplace (because this means you are responsible for the sales packaging used for your products) and/or b) fill and distribute the mail-order packaging yourself. The responsibilities for ‘real’ drop shipping are therefore: primary sales packaging = manufacturer of the goods; mail-order packaging = wholesaler/warehouse operator, etc.

Goods sold privately are an important exception here: licensing and take-back responsibilities do not apply to the sale of goods between private citizens.

 

23. Do all online retailers have to license their packaging by law?

Yes. If you operate as an online retailer who fills packaging with goods and distributes these goods to consumers, you are required to take part in a dual system. ‘Packaging’ in this sense means sales packaging as well as mail-order packaging. You must also license your filling and padding materials, as well as packaging accessories such as parcel tape and bubble wrap. ‘Licensing’ means that you use a dual system to report the packaging volumes used for selling your products (this requires payment of a fee). This obligation applies to all online merchants – including sellers who use eBay, Amazon or etsy. There may be an exception for drop shippers – see question 22.

To license your packaging, the first step is to register your company with the Central Agency Packaging Register. You then use this registration number when opening an account with a dual system – such as Interseroh’s dual system. To complete the licensing process, you enter your estimated annual volume (in kilogrammes) for the various packaging materials you use (paper, paperboard, cardboard, plastics, glass, etc.). Following this, you have to report this exact same volume to the Central Agency (see question 7).

Once a year, you then report the actual volumes of packaging materials that you placed on the market by selling your products.

 

24. German Packaging Act 2019: What is important for brick-and-mortar retailers?

If you are a company trading in a physical store or sales outlet (often called ‘brick-and-mortar retail’) that sells its products to local customers then you do not need to license the packaging that you use. This packaging has already been licensed by the manufacturer. However, you may be asked to provide proof that you are not using extra packaging. Accordingly, you must keep records that show that the product packaging has already been licensed by your manufacturer/supplier. In addition, you should also check that the manufacturer/supplier is properly registered with the Central Agency Packaging Register. You then can ask your manufacturer/supplier to provide you with a document that proves that there is a valid packaging licence for the product in its original packaging.

As a trading company selling its own branded products, you are required to license their packaging in a dual system. Service packaging that is first filled with goods when it is handed to the consumer must also be properly licensed. This kind of service packaging is often used in bakeries, at fruit and vegetable stalls in farmers’ markets or in kiosks – for packaging food and drink in bakery bags, coffee-to-go cups, pizza boxes, carrier bags, shrink wrap, etc. (see question 17).

Please do not forget to register your company and your packaging volumes with the Central Agency. It is illegal to place packaging on the market if it has not been properly licensed. Applications for the registration number required should be made well in advance of 1 January 2019 at www.verpackungsregister.org/en/.

 

25. German Packaging Act 2019: I sell on eBay and Amazon – what do I need to know?

According to the German Packaging Act, all ‘initial distributors’ (see question 5) of sales packaging that is normally disposed of as household waste by consumers must license their packaging. The obligation therefore also applies to distributers of mail-order packaging such as shipping cartons and to small online traders selling on eBay, Amazon or etsy.

 

26. I ship products to other countries. Do I need to license the packaging for these products in Germany?

No. The German Packaging Act (VerpackG) applies only to products that are sold in Germany. If you ship your products to other countries the German Packaging Act does not apply and the packaging does not need to be licensed in a dual system in Germany. However, as a manufacturer and distributor, you must make absolutely sure that this export packaging will not be placed on the market in Germany. According to the German Packaging Act, the packaging design or relevant shipping documents must confirm that the affected packaging is for export only. This applies as soon as the packaging is placed on the market (for export). If this packaging is provided to consumers later – and therefore has to comply with the regulations of the German Packaging Act –it then has to be properly licensed in a dual system as soon as possible.

Please note: Apart from Germany, many other countries have also introduced laws concerning the disposal and recycling of packaging materials.

The EU Packaging Directive regulates the packaging licensing within the European Union. It obliges manufacturers to organise a shared packaging take-back system. For more information on the EU Packaging Directive, please visit this link.

We also offer a full range of services for your packaging licensing needs within the European Union. EU28

27. I am a company/importer based outside Germany: do I need to license my packaging in Germany?

Yes. All imported packaging must also be licensed in Germany – because this packaging will be disposed of by consumers in Germany. The company that actually imports the packaging into Germany is responsible for the licensing. Typically, this company is the importer and not the exporter. If a foreign seller or shop owner sells directly to consumers in Germany without using a distributor, then this company is directly responsible for licensing according to the law. The same licensing laws apply to imports from EU and non-EU countries.

28. How much does it cost to license packaging in a dual system?

The fee charged to license packaging in a dual system depends on the volume and type of the packaging materials that you are using. Interseroh offers licensing agreements that start at just EUR 39. You can use our Calculator to quickly calculate your individual license fee with just a few clicks.

You can save money on your licence fee by using smaller or lighter kinds of cardboard packaging and you can replace heavy filling materials with paper fillers.

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29. Who checks the compliance with the new German Packaging Act?

The Central Agency Packaging Register is responsible for providing publicly accessible information about compliance with the Act. A public register is available that lists all of the companies that have properly registered. Companies doing business in the market can use this register to check each other, and to identify and report any ‘free riders’. Companies that do not comply with the Packaging Act will receive warnings or fines and can even be stopped from selling their products.

If there are doubts about the licensed volumes, the Central Agency can also check these details and request additional documents. The Agency may also request a Declaration of Compliance even for companies whose volumes are under the limit. Licensed packaging volumes for 2018 are checked by the Agency. If you have not licensed your packaging in a dual system or have reported the wrong volumes, this may be seen as a violation of packaging regulations and you can be fined up to EUR 200,000.

30. Do I have to take part in a dual system if I am a wine grower or beekeeper?

Yes. As a wine grower, you produce wine and fill this into bottles. According to the German Packaging Act, bottles are ‘sales packaging’. This means that the bottles must be licensed in a dual system. If you also pack your wine bottles into cartons and send these directly to consumers, you must also license these shipping cartons.

If your wine is picked up by a wholesaler, however, and this wholesaler packs your wine into boxes and ships it to consumers, then you only need to license your bottles. In this case, the wholesaler is responsible for licensing the shipping box.

The same applies to beekeeping businesses who fill their honey into jars and sell it by using an online shop (for example). These jars are also sales packaging, which must be licensed in a dual system. If the beekeeper uses shipping cartons to send the honey, these cartons must also be licensed.

31. What is the difference between merchants and private sellers?

Private sellers only sell to other private citizens – on eBay, for example. Unlike merchants, they do not have to register a business with the authorities.

32. Are licensing costs tax deductible?

Yes. Licensing costs are permanent and recurring payments that can be recognised as business expenses immediately. This means that these expenses are (tax) deductible business expenses.

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