Frau Annette Mustermann
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The German Packaging Act has been in force since 2019. It requires manufacturers and (online) sellers to purchase a paid licence for their sales packaging – i.e. all packaging that ultimately ends up with German private consumers – from a dual system and therefore comply with their Extended Producer Responsibility (EPR). In addition, registration with the Central Agency Packaging Register Authority (ZSVR) is mandatory.
As of July 2022, marketplace operators are obliged to check the compliance of its merchants with these requirements.
Important: These above-mentioned 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 if you are not yet legally compliant:
German Packaging Act: Your To Do's
Licensing
Start by licensing your packaging with a dual system provider. Use Lizenzero to do this through Interzero Recycling Alliance (and claim your 5% discount!) –
go here to enter your packaging volumes and start getting licensed today
✔ You’ll receive your system participation certificate to confirm your compliance
Registration
Submit your information to the LUCID Packaging Register run by the Central Agency Packaging Register.
✔ You’ll receive your LUCID registration number (EPR number) to pass on to Etsy
Data reporting
Enter the volumes you licensed and your dual system into the LUCID Packaging Register.
✔ You're done!
Packaging law, EPR, licensing & registration
The most important questions at a glance
EPR stands for "Extended Producer Responsibility". The underlying principle makes merchants and manufacturers responsible for the entire life cycle of their products and related components, including their disposal, in the service of environmental protection.
In Germany, packaging, electrical appliances and batteries are covered by the Extended Producer Responsibility of those who put them into circulation in this country.
The current high level of attention on the EPR is essentially due to the amendment of two laws: the Packaging Act (VerpackG) and the Electrical and Electronic Equipment Act (ElektroG). In the future, both will oblige marketplaces to check the compliance of their dealers with regard to the requirements. In this context, marketplace operators speak of EPR as a collective term for all three aspects.
Since the marketplaces' obligation to monitor compliance with the Packaging Act will come into effect as early as July 2022, they are currently communicating the relevant requirements to their sellers. The control obligation for electrical appliances will follow from January 2023.
The Packaging Act imposes three obligations on sellers who ship packaged products to German end consumers:
- 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 recognized dual system Interzero Recycling Alliance. Etsy sellers get 5% off the licensing fee when they use ETSY5*: Enter volumes now
- Registration in the government packaging register LUCID
- Data reporting the name of the dual system you participate in and the licensed packaging volumes to the government packaging register LUCID
- Submit your LUCID ID to any marketplace you sell on (including Etsy)
The Packaging Act was amended in July 2021. One of the changes in the law affects the operators of marketplaces: In order to create an additional control mechanism, they will have to check from July 2022 whether merchants 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 may take effect and the marketplace operators may have to restrict sales to Germany.
The Packaging Act formulates a total of three obligations for merchants of packaging in Germany (also see question #2). These include a licensing obligation (also known as the system participation obligation) and a registration obligation.
Both obligations must be fulfilled at two different contact points:
- The licensing obligation refers to the requirement of licensing your packaging through a dual system such as Interzero Recycling Alliance (via Lizenzero). After paying fees, Interzero Recycling Alliance takes over the disposal and recycling process of your packaging for you.
- The registration obligation, refers to your required registration of your business and tax information with the authority Zentrale Stelle Verpackungsregister, through the government packaging register LUCID.
You must verify compliance with the licensing obligation by entering the name of your dual system and your licensed packaging volumes in LUCID.
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