System participation obligation for manufacturers & distributors

Framework for all obligations regarding packaging throughout all member states as well as non-EU countries is the EU Directive 94/62/EC. The aim of the EU Packaging Directive is to promote recycling, increase the proportion of reusable materials in packaging products and give packaging manufacturers an incentive to use resources more sustainably. However, the laws resulting from this directive impose many requirements on you as a company, which you must comply with, otherwise you may face heavy fines. CERTIFY helps you in a time-saving and cost-effective way to be legally compliant regarding your packaging.

What do you have to do?

According to national laws for disposal and recycling of packaging material, all distributors must register with the competent authorities as well as take-back schemes to comply and finance both disposal and recycling by paying fees for sold amounts. National laws include all packaging that go to both private as well as professional consumers which include workshops, stores, schools etc. After your initial registration, you will be obliged to do regular reports and audits in order to be charged the right amounts. Reports can cost a lot of time and in some cases 14 reports per year and per country are necessary. Selling in more than 5 countries you therefore may face over 70 reports per year only for packaging. Assuming it would take you 30 minutes for one, this would make 35 hours per year! Also note that most countries enforce their own labelling and marking obligations which you must comply to, too.

Support for registration and reporting


CERTIFY accompanies you through the complete process to make your packaging marketable in Germany. This concerns for example the quantity notification, the registration with LUCID and the registration with a dual system. You will benefit from our expertise and experience, which will enable us to handle all processes for you as quickly and cost-effectively as possible. This way you can be sure that all legal requirements are met and that nothing stands in the way of trading your products.

We support you in your duties
CERTIFY offers you a legally sound solution that convinces through efficient and smooth processing. We support you so that you can concentrate your energy on the development of new products. Enjoy 100 % legal compliance!

Which products are covered by the Packaging Act or the EU Packaging Directive?

On the one hand, sales packaging that is filled with goods and outer packaging that is disposed of by the end consumer fall under the Packaging Act. Service and shipping packaging are also subject to the regulations of the law. In contrast, the packaging of goods that are exported abroad and not disposed of in Germany does not have to be registered in the Dual System. Instead, the respective legal regulations of the destination country must be considered by the end consumers or retailers there.

What are the obligations under the laws and directives?

On the one hand, the law provides for mandatory registration with LUCID (ZSVR). This register is publicly accessible and makes it easier for the authorities to prosecute breaches of duty. On the other hand, you must observe the obligation to register with a dual system. There is a fee for this participation, the amount of which depends on the amount and type of materials to be disposed of. In addition, your products or your company are subject to data reporting requirements.

Who must fulfill the obligations?

The aforementioned regulations affect manufacturersand distributorswho fill products into packaging and tradewith them, as well as e-commerce retailers who use them to ship their goods. Even as a trader who purchases goods through a wholesaler, you must comply with the VerpackG. The same applies if you import packaging products from abroad. Fulfillment service providers, on the other hand, will be exempt from the obligation from July 1, 2022 due to an amendment to the law.

Packaging laws: international full service from CERTIFY

International compliance becomes even more complicated due to the deviating legal requirements in the destination country. In order to comply with the complex requirements of the national laws and not to make any mistakes during the registration process, a careful examination of the matter is necessary. CERTIFY supports you in handling everything in a legally compliant manner. We are happy to take time for you and support you with words and deeds. Just get in touch with us!

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