What is the German New Packaging Law (VerpackG)? German New Packaging Law (VerpackG) Review

VerpackG is a new packaging law to be implemented in Germany. It will come into effect on January 1, 2019, replacing the current packaging regulations.

Scope of application

Germany's new packaging law is a legally mandatory law that requires manufacturers or sellers to register and obtain a license for the first sale of products containing packaging, including external packaging, final retail packaging, disposable containers/containers used in the catering industry, and shipping packaging materials. The packaging law requires sellers to declare the type and weight of the packaging materials sold.

It applies to all manufacturers and/or retailers who are the "first" to sell packaged products (regardless of size) directly to the end customer in a live retail operation over the counter or online.

All participants, including cross-border e-commerce/online retailers, are obliged to register under the new packaging law. Cross-border e-commerce platforms such as AliExpress, Amazon, eBay, Wish, LightInTheBox, and Dunhuang are also subject to the new packaging law.

The first packaging product (including filling materials) is brought to the German market and ends up as waste for consumers. It is subject to both VerpackV and VerpackG. The main impact of VerpackG relative to VerpackV is that the recycling scope is extended to online sellers. The principle of extended product liability applies here. These parties are therefore responsible for ensuring the collection and recycling of all relevant packaging materials.

All companies selling goods in Germany must be prepared to participate in a dual system to arrange for packaging to be returned after the goods have been used and to continue trading in Germany.

Amazon Notifications

Consequences of Not Registering

Amazon strongly recommends that all sellers complete the operation of the new German packaging law before January 1, 2019, otherwise they will not be able to store or sell products in Germany. If you do not comply with this new German law, you will face a fine of up to 50,000 euros!

If you do not register, the new requirements may create obstacles for your company to sell its products. Before the registration of Zentrale Stelle is completed, the packaged goods cannot be placed on the market in Germany. Even if your company only places one product on the market per year, these requirements still apply.

How to Register

(1) Registration requires the following information:

Company address;

Sales tax identification number (VAT number);

National identification number;

· List all brand names, first time commercial packaging on the market according to the system participation requirements. If you want to put the product on the market without a brand name, please enter the company name again (please do not enter: no name or no brand, etc.).

(2) VerpackG also makes some additional changes to existing laws:

Higher packaging collection targets;

Changes to packaging data reports must be reported to Zentrale Stelle;

· Update of packaging definition, making sales packaging clearer.

(3) In addition to the registration, the manufacturer must immediately transmit to Zentrale Stelle the relevant data on the packaging:

Registration number (previously provided by Zentrale Stelle);

· packaging materials and volumes placed on the market;

The name of the packaging scheme to which the manufacturer has subscribed to fulfill its extended producer responsibility;

· The time period for which the contract with Packaging Solutions has been agreed.