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New Germany Packaging Law – How to avoid a fine

New Germany Packaging Law – How to avoid a fine

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by Harry Wild, September 2018
Harry Wild is a Consultant in thinkstep's Recycling Compliance practice and graduated from the University of Nottingham with an MSc (Hons) in Chemistry.
A new packaging law is being introduced in Germany. The law - VerpackG - was approved last year and will replace the current Packaging Law in Germany – VerpackV - from 01 January 2019. The aim of this law, which introduces a number of new requirements, is to increase the overall transparency of the regulations for companies.

Significant Changes

As part of VerpackG, a 'central body' (Zentrale Stelle) has been assigned by the government to act as a packaging producer register, similar to the current WEEE register in Germany, EAR.
 
All manufacturers/first distributors of packaging, including packaged goods, must register with the new Zentrale Stelle through a web-platform, LUCID, prior to placing any packaging on the market in Germany. The registration must be complete by 01 January 2019, a pre-registration option is available with the Zentrale Stelle now.
 
VerpackG also introduces a number of additional changes to the current law including: 
  • Higher collection targets for packaging
  • Changes to the reporting of packaging data – must be reported to the Zentrale Stelle
  • Updates to the definitions of packaging – sales packaging is more clearly defined 

How does this affect my company? 

The new requirements could create barriers for product sales for your company if you don't register. Packaged goods cannot be placed on the market in Germany until a registration with the Zentrale Stelle has been completed. These requirements still apply even if your company only places one item on the market each year.
 
Your company could be subjected to significant fines in Germany of up to €200,000 for failing to register and €10,000 for any missed declarations. 

How do I ensure my company complies? 

The new law prohibits companies from transferring the registration and reporting requirements to a third-party (i.e. compliance schemes) –  they can assist you but the ultimate responsibility lies with the manufacturer/first distributor.

To ensure that you complete the registration successfully and therefore reduce the risk of affecting your product sales in Germany, EC4P can assist you in preparing the documents and provide detailed instructions on how you can carry out the LUCID registration for your company.

To request a step-by-step guidance document and for more information please contact us.

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