Do you sup­p­ly packa­ged goods for sale in Ger­ma­ny? If so, you are sub­ject to this sta­tu­to­ry obli­ga­ti­on. Here is ever­y­thing you need to know.

The Ger­man Pack­a­ging Act

Under the Pack­a­ging Act, pack­a­ging com­pli­ance is man­da­to­ry for both pro­du­cers and dis­tri­bu­tors who bring sales pack­a­ging into cir­cu­la­ti­on in Ger­ma­ny. In other words, anyo­ne who fills sales pack­a­ging with goods for the first time and dis­tri­bu­tes the­se packa­ged goods, typi­cal­ly resul­ting in the pro­duc­tion of was­te at a pri­va­te end cus­to­mer, must report this pack­a­ging (for inclu­si­on in a dual sys­tem).

This type of pack­a­ging is also refer­red to as “pack­a­ging sub­ject to sys­tem par­ti­ci­pa­ti­on requi­re­ments.”

What is a dual sys­tem?

A dual sys­tem ensu­res that pack­a­ging sub­ject to sys­tem par­ti­ci­pa­ti­on requi­re­ments can be pro­per­ly coll­ec­ted from pri­va­te end cus­to­mers and sor­ted, befo­re as much of it as pos­si­ble is recy­cled or reu­sed. The­re are dif­fe­rent dual sys­tem pro­vi­ders in Ger­ma­ny; they are all sub­ject to the terms of the Pack­a­ging Act.

Pro­du­cers and dis­tri­bu­tors pay a fee to their cho­sen dual sys­tem, which covers the coll­ec­tion, sort­ing and recy­cling of their sales pack­a­ging. The fee is depen­dent on the weight, mate­ri­al type and volu­me of sales pack­a­ging that is brought into cir­cu­la­ti­on. 

All pro­du­cers and dis­tri­bu­tors who­se pack­a­ging ends up as was­te with pri­va­te end cus­to­mers must include this pack­a­ging in a dual sys­tem. 

Noven­tiz Dual

Dual sys­tems such as Noven­tiz Dual have come into exis­tence becau­se pro­du­cers, dis­tri­bu­tors and mail order/online retail­ers are unable to ensu­re pack­a­ging com­pli­ance by them­sel­ves. A dual sys­tem ensu­res that pack­a­ging can be pro­per­ly coll­ec­ted from pri­va­te end cus­to­mers and sor­ted, befo­re as much as pos­si­ble of it is recy­cled or reu­sed. The use of the sys­tem by pro­du­cers and dis­tri­bu­tors is paid for through a fee, the amount of which depends on the weight (mass), mate­ri­al type and volu­me of the sales pack­a­ging. 

Sin­ce 1 Janu­ary 2017, Noven­tiz Dual has ser­ved as a dual sys­tem for the dome­stic coll­ec­tion and recy­cling of sales pack­a­ging occur­ring as was­te in some 40 mil­li­on Ger­man house­holds. 

Zen­tra­le Stel­le Ver­pa­ckungs­re­gis­ter –
the pack­a­ging regis­try

All dual sys­tems and all pro­du­cers (first dis­tri­bu­tors, online retail­ers, importers, etc.) are moni­to­red on an ongo­ing basis by the Zen­tra­le Stel­le Ver­pa­ckungs­re­gis­ter (ZSVR), refer­red to in Eng­lish as the pack­a­ging regis­try. Anyo­ne can check the public regis­ter (LUCID) free of char­ge to veri­fy that a pro­du­cer has pro­per­ly met its sta­tu­to­ry obli­ga­ti­ons. Pro­du­cers who do not ensu­re com­pli­ance may be sub­ject to hea­vy fines.

Stay on the safe side with Noven­tiz

Report your pack­a­ging online now in Eng­lish. 

What pack­a­ging is sub­ject to sys­tem par­ti­ci­pa­ti­on? 

Gene­ral­ly, all sales, ship­ping, ser­vice and secon­da­ry pack­a­ging that results in was­te at the level of the pri­va­te end cus­to­mer is con­side­red to be sub­ject to sys­tem par­ti­ci­pa­ti­on. Only trans­port pack­a­ging that remains exclu­si­ve­ly with com­mer­cial agents does not have to be included in the sys­tem. 

For the pur­po­ses of the Pack­a­ging Act, pri­va­te end cus­to­mers are both pri­va­te house­holds and “com­pa­ra­ble was­te-pro­du­cing sources”. The­se include hos­pi­ta­li­ty venues, small food pro­du­cers, hotels, can­teens, archi­tects, bee-kee­pers, ice-cream pro­du­cers and admi­nis­tra­ti­ve offices such as insu­rance agents, tax advi­sors and law firms. Agri­cul­tu­ral ope­ra­ti­ons and craft busi­nesses are also included. 

• Pro­dukt­kar­tons, die zusam­men mit dem Pro­dukt im Regal ste­hen
• Sty­ro­por­scha­len in einer Pro­dukt­box
• Plas­tik­tü­ten
• Chips­tü­ten
• Geträn­ke-Dosen

• Ship­ping pal­lets
• Pla­s­tic wrap
• Pla­s­tic straps
• Card­board covers
• Woo­den boxes

• Pla­s­tic shop­ping bags
• Take-away cups
• Bak­ery bags

• Car­ry boxes (e.g. beer car­ri­ers)
• Pla­s­tic pack­a­ging con­tai­ning seve­ral bars of cho­co­la­te
• Ciga­ret­te papers

• Card­board boxes
• Pack­ing chips
• Shred­ded paper
• Ship­ping enve­lo­pes

Who has to report pack­a­ging for the pur­po­ses of pack­a­ging com­pli­ance?

Whe­ther or not a pro­du­cer or dis­tri­bu­tor is requi­red to report sales pack­a­ging depends on who first brings the pack­a­ging that is sub­ject to sys­tem par­ti­ci­pa­ti­on requi­re­ments into cir­cu­la­ti­on to Ger­ma­ny. The­r­e­fo­re, com­pa­nies that only pro­du­ce the basic pack­a­ging mate­ri­al are not con­side­red to be pro­du­cers in the con­text of the Pack­a­ging Act.

Do you have pack­a­ging that is sub­ject to com­pli­ance?

Find out here online.

How much does pack­a­ging com­pli­ance cost?

The fee depends on the volu­me of sales pack­a­ging brought into cir­cu­la­ti­on and on the type of pack­a­ging mate­ri­al.
You must include all pack­a­ging mate­ri­als:

How are the volu­mes cal­cu­la­ted?

When you sign a con­tract you must pro­vi­de a fore­cast of the volu­me of sales pack­a­ging you expect to bring into cir­cu­la­ti­on for the calen­dar year. The volu­me of pack­a­ging mate­ri­al is expres­sed in kilo­grams. The­re are two approa­ches: 

You know the weight (mass) of the pack­a­ging that you have used.

Mul­ti­ply the weight of an indi­vi­du­al packa­ge by the num­ber of packa­ges that have been brought into cir­cu­la­ti­on. The unit weight should be lis­ted by your pack­a­ging sup­pli­er, in your cus­to­mer account for exam­p­le.

You do not have any infor­ma­ti­on about the pack­a­ging weight.

Weigh one item of pack­a­ging that is sub­ject to the sys­tem par­ti­ci­pa­ti­on requi­re­ments, and mul­ti­ply this by the num­ber of items. The result of this cal­cu­la­ti­on is the total weight of mate­ri­al brought into cir­cu­la­ti­on.

You can use our cal­cu­la­tor tool at Ver­pa­ckung Direkt to cal­cu­la­te the fee you need to pay for your spe­ci­fic volu­me of pack­a­ging. This tool cal­cu­la­tes the pri­ce and cos­ts for your volu­mes and types of pack­a­ging mate­ri­al.

Would you like to report your pack­a­ging?

Use our cal­cu­la­tor tool here. 

How do I report my sales pack­a­ging?

You need to meet your obli­ga­ti­ons under the Pack­a­ging Act befo­re you even fill and dis­tri­bu­te your first pack­a­ging with goods. Here are five easy steps to report­ing your pack­a­ging:

Using NOVENTIZ to ensu­re pack­a­ging was­te com­pli­ance in Ger­ma­ny

Sound advice at all times

NOVENTIZ is per­fect if you are loo­king for per­so­nal advice and a hass­le-free pack­a­ging com­pli­ance pro­cess. Do you still have ques­ti­ons? No worries! Your per­so­nal account mana­ger will be available at all times to help you with report­ing your sales pack­a­ging. We will defi­ni­te­ly find a solu­ti­on to your needs. 

Your one-stop shop 

NOVENTIZ does more than just report sales pack­a­ging and trans­port pack­a­ging dis­po­sal. As a cer­ti­fied and audi­ted dis­po­sal ser­vices pro­vi­der, we also look after site dis­po­sal and hand­le was­te elec­tri­cal items and bat­te­ries. 


If you are a first dis­tri­bu­tor of pack­a­ging that will result in the pro­duc­tion of was­te with the pri­va­te end cus­to­mer (e.g. “yel­low bag”/“yellow bin”) you must regis­ter with the Zen­tra­le Stel­le Ver­pa­ckungs­re­gis­ter pack­a­ging regis­try and sign up to one of the dual sys­tems. 

The­re is no mini­mum; the amount of pack­a­ging sub­ject to sys­tem par­ti­ci­pa­ti­on requi­re­ments that you bring into cir­cu­la­ti­on is not important. As soon as you fill your first pack­a­ging with goods and/or dis­tri­bu­te your first pack­a­ging, you must sign up to a dual sys­tem such as the one ope­ra­ted by NOVENTIZ. The­re are no excep­ti­ons. Dis­tri­bu­tors, pro­du­cers, online retail­ers and small and micro busi­nesses have to report their sales pack­a­ging, just like eBay and Ama­zon. 

We recom­mend that you report your pack­a­ging sub­ject to sys­tem par­ti­ci­pa­ti­on requi­re­ments at the begin­ning of the year, as the com­pli­ance sys­tem appli­es for a calen­dar year. At that point you sim­ply have to pro­vi­de an esti­ma­te of the sales pack­a­ging you intend to bring into cir­cu­la­ti­on. The actu­al fee to be paid will depend on the type and weight (mass) of pack­a­ging actual­ly pla­ced on the mar­ket. 

NB: make sure you regis­ter and sign up befo­re you start sel­ling or pro­du­cing goods. You must have alre­a­dy done this befo­re dis­tri­bu­ting pack­a­ging for the first time!

Report­ing will gene­ral­ly cover one calen­dar year. That means that even if you report your pack­a­ging part way through the year it will be effec­ti­ve retro­s­pec­tively from 1 Janu­ary. Most of the dual sys­tems in ope­ra­ti­on the­r­e­fo­re ope­ra­te on a con­tract peri­od run­ning from 1 Janu­ary to 31 Decem­ber.

If you have for­got­ten to report your pack­a­ging sub­ject to sys­tem par­ti­ci­pa­ti­on requi­re­ments in good time, you should rec­ti­fy this as quick­ly as pos­si­ble. The pen­al­ties for non-com­pli­ance include fines and even a ban on sales. To sign up for a peri­od that has alre­a­dy ended, sim­ply enter the actu­al volu­me of pack­a­ging brought into cir­cu­la­ti­on for the cor­re­spon­ding year. This Year-end Quan­ti­ty Report must be sent to us as your dual sys­tem ope­ra­tor and to the Zen­tra­le Stel­le Ver­pa­ckungs­re­gis­ter pack­a­ging regis­try. 

The­re are no mini­mum thres­holds for pack­a­ging below which pro­du­cers or dis­tri­bu­tors are exempt from the report­ing obli­ga­ti­on. You must report your sales pack­a­ging as soon as you fill your first box. 

Howe­ver, the­re is a upper thres­hold for pack­a­ging brought into cir­cu­la­ti­on abo­ve which an extra obli­ga­ti­on under the Pack­a­ging Act appli­es, along­side regis­tra­ti­on and report­ing. 

Orga­ni­sa­ti­ons pro­du­cing in excess of this volu­me of pack­a­ging are requi­red to sub­mit a “Decla­ra­ti­on of com­pli­ance”. This must be con­firm­ed by a regis­tered expert, audi­tor, tax advi­sor or cer­ti­fied accoun­tant and sub­mit­ted to the Zen­tra­le Stel­le. 

The thres­hold for the decla­ra­ti­on of com­pli­ance is set at the fol­lo­wing levels per year: 

  • Glass: 80,000 kg or abo­ve
  • Paper, paper­board, card­board: 50,000 kg or abo­ve 
  • Pla­s­tic, metal, com­po­si­tes (total): 30,000 kg or abo­ve 

No. You have to have a regis­tra­ti­on num­ber befo­re you can sign up for a con­tract with one of the dual sys­tems. 

This is man­da­to­ry: regis­ter first, then sign up.

Yes, ser­vice pack­a­ging is cover­ed by a spe­cial rule. The dif­fe­rence is that ser­vice pack­a­ging is not fil­led with goods until the point of sale, for exam­p­le when a loaf is pla­ced in a bag by the sales assistant at the baker’s shop. The­r­e­fo­re, if the final dis­tri­bu­tor, in this case the baker’s shop, is the one to fill the ser­vice pack­a­ging and bring it into cir­cu­la­ti­on, the shop does not neces­s­a­ri­ly have to have its own regis­tra­ti­on num­ber for inclu­si­on in one of the dual sys­tems. Ins­tead, it can use pre­vious­ly repor­ted pack­a­ging from its sup­pli­er or request that the upstream dis­tri­bu­tor report the pack­a­ging for inclu­si­on in a dual sys­tem in the upstream distributor’s own name and regis­tra­ti­on num­ber. 

Note: ship­ping pack­a­ging always has to be repor­ted.

Of cour­se! Used pack­a­ging is often per­fect­ly ser­viceable and it would be a was­te to sim­ply dis­po­se of it. Howe­ver, you must remem­ber to re-report it to one of the dual sys­tems if you want to use it when sel­ling goods to an end cus­to­mer. Why? When you fill the pack­a­ging with your goods it beco­mes sales pack­a­ging or dis­tri­bu­ti­on pack­a­ging. 

The sys­tem par­ti­ci­pa­ti­on requi­re­ment for reu­sed pack­a­ging is only wai­ved if the dis­tri­bu­tor shows that the used pack­a­ging has alre­a­dy been repor­ted to one of the sys­tems. 

We recom­mend that you stay on the safe side and report the full quan­ti­ty of pack­a­ging you need, to ensu­re that you do not have to worry about being fined. 

  • Do for­eign busi­nesses or importers have to report their pack­a­ging in Ger­ma­ny?

Yes. Any pack­a­ging that is impor­ted into Ger­ma­ny must be repor­ted under the Pack­a­ging Act. This is becau­se it falls under the scope of the Pack­a­ging Act (i.e. Ger­ma­ny) as was­te pro­du­ced at the pri­va­te end cus­to­mer. The report­ing obli­ga­ti­on lies with the com­pa­ny that imports the rele­vant pack­a­ging into Ger­ma­ny. This is gene­ral­ly the importer which ships the goods into the coun­try or cau­ses them to be impor­ted. 

For­eign pro­du­cers and dis­tri­bu­tors who sell direct­ly to cus­to­mers in Ger­ma­ny are obli­ged to report their pack­a­ging. The­re is no dif­fe­rence here bet­ween importers loca­ted in other Mem­ber Sta­tes of the EU and tho­se from non-EU count­ries. 

Have you got any other ques­ti­ons about pack­a­ging com­pli­ance in Ger­ma­ny?

Send us an e‑mail here.