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Packaging Licensing FAQ
Here you will find answers to frequently asked questions about extended producer responsibility and the packaging license in Germany.
Still questions about packaging licensing? Here are a few more answers to find
No, both mean the same thing. They are merely different formulations. "Packaging licensing" is the common term, "system participation" is the official legal term.
Packaging licensing makes a relevant contribution to sustainability because your financial contribution ultimately ensures that packaging or its recyclable materials can be recycled. The licensing fees ensure that the dual systems can provide the structures necessary for recycling. This means collection, sorting and recycling. Packaging is one of the most common types of waste in Germany. And the trend is still rising. Moreover, the production of packaging requires large quantities of primary raw materials - for example, oil in the case of plastic packaging. For this reason alone, it is sustainable to use packaging disposed of by the end consumer to produce recycled raw materials. This makes a significant contribution not only to the conservation of primary raw materials, but also to CO2 reduction and thus to climate protection.
In principle, these distinctions are superfluous with regard to packaging licensing. This is because, according to the latest Packaging Act, all packaging that is placed on the market for the first time and can end up at the end consumer must be licensed in principle. Only transport packaging that is used, for example, to supply wholesalers and therefore does not reach the end consumer is exempt from the licensing obligation.
"Erstinverkehrbringer" (first distributer) is a term from the Packaging Act. It refers to natural or legal persons who put a packaging product or packaged goods into circulation on the German market for the first time. If you take on this role from the perspective of the law, you are responsible for complying with the regulations of the Packaging Act. This means, among other things, that the packaging is fed into the dual system and that you carry out the packaging licensing for this purpose.
This means that you, as the initial distributor in Germany, pay a participation fee (licence fee) to a dual system. This money is used to finance the disposal of packaging waste generated in households or comparable sources. These include accommodation establishments, canteens, large kitchens, bakeries as well as craft and forestry businesses.
The capacity as first distributor can fall to various market actors such as manufacturers, importers or traders. It does not matter which products you trade in. For example, if you operate an online shop for ceramics and send your goods in shipping packaging, you may also become a first distributor. The prerequisite is that it is packaging that has not yet been placed on the German market.
The Packaging Act stipulates that all packaging that typically accumulates at private end consumers must be licensed. However, establishments that are not directly associated with the term "end consumer" are also considered to be private end consumers. Restaurants and canteens, for example.
In such a case, you will face severe fines of up to six figures. In addition, you will be prohibited from selling products in unlicensed packaging. You should avoid both of these at all costs, even as a small business, because it can quickly threaten your existence. Especially since participation in a dual system definitely doesn't cost the earth. Especially smaller online shops or companies of a similar size have an annual financial outlay of well under 100 euros.
The Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR) is something like the regulatory office for packaging licensing. It checks that everyone who is obliged to participate in the dual system actually complies with this obligation. The whole thing is done with a maximum of transparency. All companies registered with the ZSVR can be viewed publicly on the LUCID portal. Ultimately, this ensures fair competition.
LUCID is a database established by the foundation "Zentrale Stelle Verpackungsregister" (Central Agency Packaging Register – ZSVR). If you produce packaging, trade with it or sell packaged products, your company must register with LUCID and deposit the packaging license information. In this way, LUCID plays a key role in enabling the ZSVR and the Umweltbundesamt (Federal Environmental Office Germany) to monitor whether companies are complying with the Packaging Act.
For private end consumers, LUCID only plays an indirect role. They can check in the publicly viewable directory whether a (packaging) producer, importer or distributor is properly registered.
The Packaging Act applies in principle to manufacturers. However, the definition of manufacturer in the law is broad and also includes actors who are not directly involved in the manufacturing process of the packaging. On the one hand, producers of packaging must comply with the law. On the other hand, the Packaging Act affects your company if you fill packaging with goods and place them on the market for the first time with commercial intentions, i.e. if you are a trading company or online retailer. The commercial purpose includes not only the sale to your customers, but also sales promotion measures such as free samples.
If you import goods that are already pre-packaged, the Packaging Act also applies. The decisive factor is that your packaging ultimately accumulates as waste at the end consumer or comparable points. Bakeries, large-scale catering establishments and canteens, as well as craft and forestry enterprises are considered comparable sources of waste. From the point of view of the law, they are on an equal footing with private households, so that you must license your packaging and declare the quantities delivered to LUCID if businesses of the aforementioned types are among your customers.
The Packaging Act does not only apply to companies that are based in Germany. If your company is located abroad and you want to place packaging on the German market, you must carry out packaging licensing just like your German colleagues.
If you are one of the producers according to the definition in the Packaging Act, you must carry out packaging licensing and register in the "LUCID" register with the relevant data. This therefore means that you must register if you are a packaging producer or deal in packaged goods as a trader, importer or mail order/online retailer.
If you produce or sell service packaging that is filled with goods by your commercial customers in close proximity to the point of sale, you may also need a packaging license. Your customer has the option of outsourcing the packaging licensing obligation to you as an upstream economic stage. In this context, the law refers to a pre-share.
The law means, among other things, an obligation for initial distributors to license packaging. It was passed with the intention of making companies responsible for packaging in terms of product stewardship. The aim is for you, as a packaging manufacturer, to address in advance how your product can be disposed of at the end of its life cycle.
The dual system dates back to the 1990s, when separation into household waste and recyclable raw materials such as paper, glass and plastic was introduced in Germany. While public waste management companies continue to be responsible for household waste, private-sector companies take over disposal and recycling of the remaining (packaging) waste. The system thus consists of two players, which is why it is referred to as "dual". As a distributor or manufacturer of packaging, you can choose for yourself which provider from the dual system you want to work with.
There are currently a total of twelve dual systems in Germany. You can cooperate with one of the following providers:
- EKO-PUNKT GmbH & CO. KG / Easy-Lize
- Landbell AG für Rückhol-Systeme
- Noventiz Dual GmbH
- PreZero Dual GmbH
- Reclay Systems GmbH
- Recycling Dual GmbH
- Veolia Umweltservice Dual GmbH
- Zentek GmbH & Co. KG
- INTERSEROH+ GmbH
The Packaging Act distinguishes between packaging that is subject to system participation and packaging that is not subject to system participation. The first category includes:
- Sales packaging
- Service packaging
- Shipping packaging
- Outer packaging that bundles several products into one sales unit
For these products, as the initial distributor, you must go through packaging licensing. However, as of July 1, 2022, you must also declare in LUCID the quantities of packaging you put into circulation that are not subject to system participation. This concerns:
- Transport packaging
- Reusable packaging
- Deposit-liable one-way beverage bottles
- Sales and outer packaging that is not generated as waste in private households
- Packaging of products containing harmful substances
For single-use plastic beverage bottles, the Packaging Act also stipulates that they must be made of at least 25 percent recyclate from Jan. 1, 2025, and at least 30 percent from Jan. 1, 2030. Single-use glass or metal beverage containers are not affected by this requirement.
If your company uses transport packaging to ship your goods to business customers, you must take it back and recycle or dispose of it properly.
Source: https://www.haendlerbund.de/en/
You can do the licensing online right here at EASY-LIZE. This only takes a few minutes and gives you the certainty that you are legally protected and comply with the legal requirements.
The price of your license depends on the total weight of the packaging you put into circulation. On the other hand, the raw material or packaging fraction (the material) plays a role. The cost is calculated based on the amount of packaging in kilograms, with different prices depending on the material. You can choose between paper/cardboard, ferrous metals, plastics and other materials, thus specifying exactly what the packaging is made of.
In the early days of the Dual System, Der Grüne Punkt was the monopolist in the household packaging disposal sector. Since the market was opened up to other providers, the Green Dot brand has lost importance. Since 2009, the Green Dot mark as a sign of system participation on packaging is no longer obligatory and in some countries it is no longer allowed due to the possibility of misleading, because the trademark Der Grüne Punkt is not a sign of quality for environmentally friendly packaging but merely a sign that the user makes payments to the company Der Grüne Punkt.
Therefore, if the well-known symbol of this trademark is printed on a packaging, it only means that the producer cooperates with the company "Der Grüne Punkt" and pays a fee for the use of the trademark. However, this does not mean that disposal is particularly environmentally friendly. Nowadays, there are enough other providers in the dual system, such as EKO-PUNKT, so that you as an entrepreneur can choose the best offer.
The Eco Modulation Fee is an instrument of national and European circular economy policy designed to create financial incentives to make packaging as recycling-friendly as possible and to promote the use of secondary raw materials and renewable raw materials.
The Eco Modulation Fee is paid by the distributors of sales packaging and is dependent on the recyclability of the packaging. The amount of the payment is determined by the national authorities.
In Germany, this will most likely take the form of a fee that will be paid into a fund to be set up. Even if the organisation, threshold values and amount of these surcharges have not yet been decided politically, the EKO-PUNKT PackLab already allows you to simulate the additional costs for packaging with reduced recyclability.
This means that distributors, manufacturers and importers already have an overview of future additional costs and can react at an early stage and take this factor into account in packaging management and packaging development.
In Germany, an importer must pay for a packaging licence in order to comply with the legal requirements of the Packaging Act (VerpackG). Here are the main reasons:
1. Responsibility for packaging placed on the market
Producer responsibility: The Packaging Act places responsibility for the disposal and recycling of packaging on the companies that place it on the market. An importer is considered to be the first distributor, as they introduce the packaged goods onto the German market.
2. Ensuring the financing of disposal
Dual systems: Imported packaging must participate in dual systems in the same way as packaging produced in Germany. These systems finance the collection, sorting and recycling of packaging waste. The licence fees paid by the importer help to cover these costs.
3. Environmental protection and resource conservation
Recycling and reuse: Payment of the licence fees ensures that the imported packaging is properly recycled and reused. This helps to reduce waste and conserve natural resources.
4. Compliance with legal requirements
Packaging Act (VerpackG): The law stipulates that all those who place packaged products on the German market must register and licence their packaging. This also applies to importers who import packaging from abroad.
5. Avoidance of fines and penalties
Legal compliance: Failure to comply with the licensing obligation can lead to significant legal consequences, including fines and distribution bans. By paying the licence fees, the importer ensures that it complies with the legal requirements and avoids penalties.
6. Fair competition
A level playing field: The licensing obligation ensures that all companies, regardless of whether they produce in Germany or import, bear the same costs for the disposal and recycling of packaging. This prevents distortions of competition and ensures fair market conditions.
7 Transparency and traceability
Registration in LUCID: Importers must register in the LUCID packaging register. This creates transparency and enables the traceability of packaging placed on the market, which contributes to better monitoring and enforcement of recycling requirements.
In summary, the obligation to pay for a packaging licence ensures that importers take responsibility for the environmentally friendly disposal and recycling of the packaging they import. This supports the objectives of the Packaging Act and contributes to a more sustainable handling of packaging waste.
All questions answered? Then license conveniently online with EASY-LIZE here now
