Are you familiar with VerpackG, the German Packaging Act?
In force since 1 January 2019, it is aimed at anyone who places packaging on German territory that is intended for the end consumer or for marketing.
It is therefore essential to be familiar with VerpackG if you have a company or e-commerce business that does business with Germany. If your products arrive in Germany via packaging of any kind, then this law affects you personally.
Every interested party is required to register on the LUCID portal of the Central Office (Zentrale Stelle Verpackungsregister), join the dual system and pay a fee, which is calculated according to the specific case.
You will have to submit the following information when registering:
- Name, address and contact details
- Indication of an authorised representative
- National identification code of the producer of the goods including the relevant tax code
- Indication of the brand name of the product being packaged and shipped
- Declaration of participation in a dual system
- Declaration of the veracity of the information provided
As a retailer and distributor of packaging on the Italian territory, RAJA Italia is not obliged to register.
If you purchase our packaging, please note that you only have to register if your company ships to Germany.
What is a dual system?
Dual systems are private companies that collect, sort and recycle used packaging in Germany.
The obligation to register with the Central Office is personal and must be handled personally, whereas the obligation to participate in the dual system is transferable.
This means that, in order to fulfil the legal obligation to participate in the system, the manufacturers and/or distributors of the goods can themselves enter into a contract with a dual system or instruct another party to enter into the contract (intermediary, commissioned third party, etc.).
The objective of VerpackG is to actively involve those who bring packaging materials into Germany in their recycling, reuse or disposal.
Is an Italian company required to join VerpackG if it already pays CONAI in Italy?
Yes, because packaging that is exported to Germany is no longer the responsibility of CONAI because its disposal is handled abroad and no longer in Italy.
As an Italian company, however, you can offset what you have imported and exported by asking CONAI for a refund of the environmental contribution, initially paid to them, for the packaging that was subsequently exported.
What is new for VerpackG?
This regulation has recently undergone and will undergo updates to respond to the increasing focus on sustainability.
What will change?
From 1 July 2022
- The registration obligation has been changed: all packaging must be registered, including transport packaging and reusable packaging
- The regulation also applies to those selling via e-commerce with the obligation to ensure that goods for sale on electronic platforms are not sold either via unregistered producers or in packaging that is not part of a dual system.
From January 2025
- Minimum use of recyclate will come into force
The sale of PET bottles with less than 25% recycled content will be prohibited
From 1 January 2030, the percentage must be 30%.
Complying with the legislation is crucial, firstly to support a circular economy and sustainable development, but also to avoid heavy fines of up to €200,000!