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Since July 2022, the control obligation for fulfillment service providers and online marketplaces from the amendment to the German Packaging Act (VerpackG), which came into force in 2021, has been implemented. The VerpackG obliges retailers and manufacturers to license their sales packaging for products sold to end consumers. The aim behind this is to significantly advance the circular economy in Germany and thus protect the environment.

But what exactly does the amendment mean for online retailers, especially those who sell their products via marketplaces and fulfillment service providers?

We have summarized the key information below. 

Obligations for fulfillment service providers and online marketplaces

The amendment of the German Packaging Act entailed a change in the obligations of retailers and shipping service providers. After a one-year transitional period, since July 2022, fulfillment service providers are no longer be required to license shipping packaging that is subject to mandatory system participation. Instead, the commissioning distributor (retailer) of the products is required to license the packaging in all cases. 

Fulfillment service providers and online marketplaces also have to check whether their retailers have complied with the obligations of the German Packaging Act. If retailers cannot demonstrate compliance, fulfillment service providers or online marketplaces are no longer allowed to offer, sell or ship their products. If fulfillment service providers and online marketplaces fail to comply with these obligations, they may face severe penalties.


Background to the amendment of the Packaging Act for (online) retailers, marketplaces, and fulfillment service providers

The Packaging Act obliges retailers and manufacturers to contribute to a more efficient circular economy through their license fees. This also applies to companies that export goods from abroad to Germany or sell their products in Germany with the help of fulfillment service providers and/or online marketplaces. Retailers and manufacturers who do not comply with their system participation obligation and avoid the associated costs create a competitive disadvantage for companies that properly comply with the provisions of the Packaging Act and risk warnings, fines, and sales bans. 

As many retailers from abroad use the services of fulfillment service providers and online marketplaces to sell their products in Germany, the amendment to the Packaging Act has made fulfillment service providers and online marketplaces more accountable in terms of monitoring to ensure that the measures are implemented. The provisions of the Packaging Act apply to both foreign and German companies.

Retailers’ and manufacturers’ obligations under the German Packaging Act

If retailers put product and/or shipping packaging into circulation in Germany, which then reaches the private end consumer, they must license the respective packaging. This means that they must pay a license fee to participate in a dual system (e.g. Interseroh+), which in turn takes care of sorting and recycling the packaging. This so-called ‘mandatory system participation’ can be managed quickly and easily with our partner Lizenzero, the online shop of the dual system Interseroh+.

Get your packaging licensed now!

In addition to the system participation obligation just described, the VerpackG also requires companies to register and report data to the Central Agency Packaging Register - Zentralen Stelle Verpackungsregister (ZSVR): 

  1. Obligation to register: Retailers and manufacturers who place packaging on the German market must register with the Central Agency Packaging Register (ZSVR) in the public register (Verpackungsregister) LUCID and provide the number under which they are registered with the dual system.   
  2. Obligation to report data: After selecting a dual system and licensing the sales packaging, retailers must report the name of the dual system and the licensed packaging quantities to LUCID. The information provided to the dual system must match that reported to LUCID at all times.

Conclusion: Extended obligation for more product responsibility

The regulations of the VerpackG aim to encourage more companies that put packaging into circulation to meet their obligation to license this packaging. The extended requirements also apply to online retailers who use the services of fulfillment service providers or online marketplaces. The aim is to further strengthen the recycling of packaging materials.



About Lizenzero

With the help of our partner Lizenzero, the online shop for packaging licensing of the recognized dual system Interseroh+, you can license your packaging completely online! In cooperation with byrd, we are offering an exclusive 10% discount (code GETBYRD10) for modern packaging licensing. Upgrade your business to be legally compliant in no time!

*to be redeemed on Valid until 31.12.2024. Discount on the net value of goods. No payout possible. One voucher per order and customer redeemable. No combination with other discount campaigns possible. Subsequent redemption not possible. Legal action is excluded.