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EASY-LIZE - das Portal für Verpackungslizenzierung von EKO-PUNKT - Header checken lizenzpflichtig oder nicht

Know more

Here you will find explanations of terms relating to the licensing of packaging in Germany and answers to frequently asked questions on the subject.


Looking for explanations of common terms in the industry?
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Terminology on the subject of packaging licensing explained briefly and comprehensibly

Assessment basis

The assessment basis is a technical-physical or monetary quantity that serves as the basis for calculation. In connection with packaging law or the Packaging Act, this can be, for example, the further development of a minimum standard for packaging subject to system participation in order to meet the goal of increased recyclability.

Central Agency Packaging Register (Zentrale Stelle Verpackungsregister)

The Zentrale Stelle Verpackungregister (ZSVR) is an independent authority that has the task of maintaining the packaging register and monitoring compliance with the regulations on packaging licensing within the framework of the Packaging Act. It was established on 16 May 2017 as a foundation under private law and is the operator of the LUCID database.

The ZSVR acts as a neutral intermediary between the companies and the dual systems responsible for taking back and recycling packaging.

Companies that put packaging into circulation must register with the ZSVR and report their packaging quantities. Finally, the ZSVR assumes sovereign tasks that are regulated in §26 VerpackG. These include, for example, the decision on the classification of a packaging as system participation-obligatory, as reusable packaging or as deposit-obligatory one-way beverage packaging, the transmission of data to other environmental authorities or the information of the competent federal state authorities about possible administrative offences.


A distributor is a company or person who resells products or goods to final consumers or other companies. In packaging law, the term "distributor" refers to any company that puts packaging into circulation or on the market, such as retailers, online traders or wholesalers.

In Germany, there is a participation obligation for distributors who put packaging on the market. They must participate their packaging in a dual system and pay a licence fee to fulfil their obligations under the Packaging Act. This fee is calculated according to the type of material and the quantity of packaging they put into circulation.

As distributors, companies must ensure that their packaging complies with the requirements of the Packaging Act, including system participation, correct labelling and the correct amount of recycled materials. They are also responsible for the correct collection and reporting of the packaging they put into circulation.

By licensing and using environmentally friendly packaging, distributors can help reduce environmental impact and promote the circular economy.

Dual System Germany

The dual system is a system for the collection and disposal of packaging waste in Germany. It was introduced in the 1990s to relieve the burden on household waste disposal and, in the process, to ensure that packaging waste is disposed of in an environmentally friendly manner and in a way that is fair to the polluter. It consists of privately organized waste management companies that dispose of (packaging) waste at the household level as a second system (dual system) - in addition to the existing public disposal (gray garbage can) by municipal waste management companies.

While dual systems are responsible for collecting and sorting packaging waste and ensuring that it is recycled or otherwise disposed of in an environmentally friendly manner, waste disposal companies are responsible for collecting and disposing of the remaining household waste at the municipal level.

The dual systems are financed by payments received from manufacturers and distributors of packaged products under participation agreements. These participation fees (also called license fees) cover the costs of collecting, sorting and recycling the packaging waste. The amount of the participation or license fees depends on the quantity and material type of packaging that a company puts into circulation.

The dual system achieves a high recycling rate for packaging waste. Packaging is collected, sorted and recycled, saving valuable resources and protecting the environment. Consumers can also contribute to environmental protection through the dual system by disposing of packaging correctly and making sure to buy products with environmentally friendly packaging. The dual systems' waste separation initiative explains how consumers dispose of packaging correctly.

EKO-PUNKT is one of the dual systems in Germany.

End consumer

End consumer is a term that is also frequently used in connection with packaging and the dual waste management system. It refers to the ultimate consumer of a product, i.e. the person who actually uses and consumes the product. The final consumer can also be the trade.

In the context of packaging licensing - legally participation in a dual system or system participation - end consumers play an important role because they indirectly contribute to the financing of the recycling system through the packaging they use. Under the Packaging Act, manufacturers are obliged to participate in a dual system and ensure the disposal and recycling of their packaging. The costs of this are covered by license fees paid by the manufacturers to the dual systems. These costs are ultimately passed on to the end consumer through the sales prices.

For end consumers, it is important to properly dispose of and separate packaging so that it can be returned to the recycling loop. The correct disposal of packaging not only helps to protect the environment, but also ensures that the costs of packaging licensing can be distributed as fairly as possible among all parties involved.

Exemption from packaging take-back duty "Entpflichtung"

In the context of packaging law, exemption means system participation and hereby the exemption from the packaging take-back duty. Thus, a so-called system participation obligation applies to certain packaging, such as sales packaging and shipping packaging. This obligation lies with the company that for the first time commercially sells the sales and/or outer packaging filled with goods to a third party in Germany for the purpose of distribution, consumption or use and which typically accumulates as waste at the end consumer. In order to fulfill the system participation obligation, companies must conclude a system participation agreement with an approved dual system.

This system, in turn, ensures that used packaging is taken back from private end consumers on a nationwide, regular and free-of-charge basis.

First distributor "Erstinverkehrbringer"

A first distributor is a term from packaging law and refers to a person or a company that places packaged goods on the market for the first time within the scope of the German Packaging Act. This means that the first distributor is responsible for ensuring that the packaging is properly involved in a dual system such as EKO-PUNKT and that the legal regulations are complied with.

As a first distributor, one can be, for example, a manufacturer, importer or dealer of goods that are sold packaged. Even if you send goods as an online shop operator and pack them in packaging (shipping packaging), you become the first distributor.

Packaging licensing is required by law in many countries and aims to reduce the environmental impact of packaging waste. This means that the first distributor must ensure that its packaging is reported in accordance with the relevant national legislation. This ensures that this waste is disposed of professionally and in accordance with the applicable legal provisions.

In order to guarantee this, the first distributors in Germany must participate in a dual system for their packaging and pay a participation fee (license fee) for it. The fees collected in this way are used to finance the disposal of packaging waste in the household or in household-equivalent sources.

Packaging Act Germany (VerpackG)

The Packaging Act (VerpackG) is a law that has been in force in Germany since 2019 and regulates dispensation (also system participation or packaging licensing). It replaces the previously applicable Packaging Ordinance and is intended to ensure more transparency and efficiency in this area.

The VerpackG obliges manufacturers and traders of packaging to participate in a dual system. In addition, the law lays down requirements for the recycling and recovery of packaging waste.

The aim of the VerpackG is to increase the recycling rate of packaging waste in Germany and to reduce the environmental impact of waste. It is part of the European efforts to promote the circular economy and make waste management more sustainable.

The obligations of the companies include, among other things, the regular reporting of the packaging they place on the market to the central packaging register LUCID. They must also design their packaging to be as environmentally friendly as possible and ensure that it can be recycled.

The Packaging Act is thus an important instrument for regulating packaging licensing in Germany and reducing the environmental impact of packaging waste. It is intended to help create a more sustainable circular economy and to use resources more sparingly.

The obligations of the companies include, among other things, the regular reporting of the packaging they place on the market to the central packaging register LUCID. In addition, they must design their packaging to be as environmentally friendly as possible and ensure that it is recyclable.

The Packaging Act is thus an important instrument for regulating packaging licensing in Germany and reducing the environmental impact of packaging waste. It is intended to help create a more sustainable circular economy and to use resources more sparingly.

We have made the legal text of the Packaging Act (VerpackG) available to you here (German).

"Grüner Punkt"

In 1990, the company Der Grüne Punkt set up and organized the world's first dual system for end-consumer-oriented, high-quality recycling of sales packaging as a monopoly in order to free industry and trade from their obligation to take back and recycle according to the statutory packaging ordinance in force at the time. The "Der Grüne Punkt" brand, which was created as a sign of system participation, is protected worldwide and was formerly an internationally known trademark. After the end of the monopoly and the opening of the market for other dual systems, such as EKO-PUNKT, the Grüner Punkt brand lost importance.

Since 2009, the green dot is no longer mandatory as a sign of system participation on packaging and is no longer permitted in some countries due to the possible misleading effect, because the green dot brand is not a quality mark for environmentally friendly packaging but merely a sign that the user is making payments to the company Der Grüne Punkt provides.


An importer is a company that imports goods or products from another country and sells them in its own country. The importer can either act as an intermediary and resell the goods or use or process the products himself as the end consumer.

The importer plays an important role in the area of ​​packaging licensing (system participation), as he is usually responsible for compliance with country-specific packaging regulations and regulations. Importers must ensure that the packaging they import complies with the relevant recycling and disposal regulations and, if necessary, is licensed accordingly. To do this, they usually have to work closely with the manufacturers and suppliers of the packaging.

Since the importer often acts as the first link in the supply chain, he is also obliged to pass on the information about the packaging to the subsequent links in the supply chain. This enables everyone involved to ensure that the packaging is properly licensed and disposed of.


Intermediaries are companies that operate between manufacturers and traders, purchasing and reselling goods on their own account. They play an important role in the value chain and enable products to be distributed efficiently and cost-effectively.

In the area of packaging licensing (system participation), intermediaries are often tasked with fulfilling registration and reporting obligations. They must ensure that the packaging they trade in is properly licensed and registered and that corresponding data is forwarded to the relevant bodies. They must also ensure that they only purchase packaging from producers who also comply with their obligations.

Intermediaries can take various forms, including wholesalers, importers or distribution agencies. They often have close contact with manufacturers and customers and can thus provide valuable information about market needs and new products.

It is important to note that intermediaries not only play an important role in packaging licensing, but also in environmental compliance and promoting sustainability. They can help reduce the environmental footprint and promote a sustainable supply chain by using environmentally friendly packaging and materials.


LUCID is the online portal of the "Zentrale Stelle Verpackungsregister (ZSVR)"  - the central office of packaging register in Germany - for the implementation of the Packaging Act. The LUCID portal is an important platform for manufacturers and distributors of packaging as it represents a central database in which all information on packaging licensing must be recorded. Manufacturers and distributors must provide their data and licenses here to demonstrate their compliance with the Packaging Act. By collecting this data, the ZSVR and the Federal Environment Agency can check whether companies are meeting their packaging licensing obligations and take enforcement action if necessary.

LUCID has no direct meaning for consumers. However, companies that report their packaging to the LUCID portal help improve their environmental footprint by ensuring their packaging is properly disposed of and recycled.


Recyclability refers to the property of packaging materials to be reused or recycled after use. If a package is considered recyclable, it means that it is designed so that its materials can be returned to the manufacturing process after disposal.

Usually, the goal is to reduce environmental impact by minimising waste and conserving natural resources. For example, materials such as paper, cardboard and plastic can be reused or recycled to make new products.

However, the recyclability of packaging often depends on various factors, such as the type of materials, the complexity of the packaging and the availability of recycling systems. Some packaging is more difficult to recycle than others and may require special processes or equipment.

Therefore, it is important that manufacturers and consumers also consider recyclability in the design when selecting packaging materials in order to minimise environmental impact and promote a more sustainable use of resources.

In Germany, recyclability is determined on the basis of the minimum standard for the assessment of recyclability of packaging subject to system participation pursuant to Section 21 (3) VerpackG. This minimum standard is updated annually.


The term "manufacturer" is of great importance in packaging law. In this context, a manufacturer is anyone who commercializes packaging for the first time. Alternatively, one can therefore also speak of a first distributor. It does not matter whether the packaging is new or used, or whether the packaging was manufactured in Germany or abroad.

Manufacturers are required to register in the LUCID database in order to be able to place their packaging on the market in accordance with the law. Manufacturers are also required to license their packaging and participate in the dual system to ensure their packaging is properly recycled at the end of its life.

Manufacturers are therefore responsible for the entire life cycle of their packaging and must ensure that it can be disposed of in an environmentally friendly manner.

If packaging is not disposed of properly, this can lead to environmental pollution. Especially when they end up in nature – this is referred to as littering – and only break down there very slowly. It is therefore important that manufacturers meet their responsibilities and comply with legal requirements in order to protect the environment and promote a sustainable circular economy. It is therefore important that manufacturers fulfill their responsibility and comply with legal requirements in order to protect the environment and promote a sustainable circular economy.

Registration obligation / Licensing obligation

The registration or licensing obligation is a central aspect of the Packaging Act, which must be observed by manufacturers and distributors of packaging and packaging materials.

The registration obligation refers to the reporting of packaging placed on the market to an approved register (LUCID). This is to ensure complete traceability of the packaging. Manufacturers and distributors must contractually agree with a dual system (system participation) and pay the costs for the disposal of their packaging to their dual system. These costs depend on the quantity and type of packaging used. The commissioned dual system organises and coordinates the disposal of the packaging and ensures that it is recycled or disposed of in an environmentally sound manner.

Failure to comply with the registration or participation obligation can lead to heavy fines or a ban on distribution. It is therefore important that manufacturers and distributors address the requirements of the Packaging Act at an early stage, register and participate their packaging in a dual system (participation obligation) in order to comply with all legal requirements.

Packaging Ordinance (VerpackV)

The Packaging Ordinance (VerpackV) was the first set of regulations that stipulated the responsibility of manufacturers for the disposal of their products (extended producer responsibility). It was valid from 1991 to 2019 and was amended several times until it was replaced by the Packaging Act (VerpackG) after its expiry.

Like the currently valid Packaging Act, the Packaging Ordinance already had the goal of minimising the environmental impact of packaging waste and increasing recycling rates. All distributors, for example manufacturers, importers or traders of packaging, were subject to the ordinance.

The Packaging Ordinance stipulated that companies have a licensing obligation for their packaging. This means that they have to pay a licence fee for each packaging they put into circulation. This fee is collected - even today - by a dual system that takes care of the collection, sorting and recycling of the packaging waste.

The Packaging Ordinance also set recycling quotas that must be met by the dual systems. These quotas differ depending on the material type of the packaging and are intended to ensure that a large part of the packaging waste is recycled and reused. Companies must therefore ensure that their packaging is as recyclable as possible.

Outer packaging / Repackaging

An outer packaging is an additional packaging that is placed around an already packaged product. Unlike primary packaging, which directly surrounds the product, the primary purpose of outer packaging is to protect and handle the product during transportation and storage.The use of outer packaging is often necessary to ensure the stability and protection of products, especially heavy or bulky items. However, it can also lead to increased packaging waste, especially if the outer packaging is not recycled.

According to the Packaging Act, companies are also obliged to participate in a dual system such as EKO-PUNKT for their outer packaging, if it is usually generated by the end consumer. The participation fees are based on the amount and type of packaging used. Companies can also optimise their packaging to reduce the amount of material needed and thus minimise packaging waste.

There are different materials from which outer packaging can be made, such as cardboard, plastic or wood. The choice of material depends on various factors such as the product, transport and storage conditions and recycling possibilities. Some materials are more recyclable than others and can therefore be a more sustainable option.

There are various materials from which outer packaging can be made, such as cardboard, plastic or wood.
The choice of material depends on various factors such as the product, transport and storage conditions and recycling possibilities. Some materials are more recyclable than others and can therefore be a more sustainable option.


Recycling refers to the process by which waste products are reprocessed and transformed into input materials for new products or into new products. In terms of packaging, it involves collecting, sorting and recycling the various materials such as paper, cardboard, plastic or metal after use. The goal is to conserve resources and reduce environmental impact.

During recycling, the recyclable packaging waste is first automatically sorted and then divided into different fractions. These fractions are then further processed in special plants and turned into new raw materials or products.

The so-called closed-loop recycling system plays an important role here. Here, recycled materials are reused in a closed-loop system without the need for new raw materials. This reduces the consumption of limited resources and produces less waste.

However, recycling is not the only solution for the sustainable use of packaging. Reducing packaging reusing packaging or designing for recycling are other important approaches to reduce the environmental impact of packaging waste. 

Recycling has not only ecological advantages, but also economic ones. By reusing materials, costs are saved that would be incurred in new production. Disposal costs are also reduced as less waste ends up in landfills.

However, recycling is not the only solution to sustainable packaging licensing. Reducing packaging, reusing packaging or using biodegradable materials are also other important approaches to reducing the environmental impact of packaging waste.

Packaging licence

The colloquially used term packaging licence means in the legal sense the participation of packaging subject to system participation in a dual system such as EKO-PUNKT. Packaging licensing - or better system participation - is a private-sector agreement between a distributor of packaging and a dual system. A packaging licence is not an official authorisation. In a participation agreement, the dual systems regulate the mutual rights and obligations and, in particular, the amount of the participation fees, which are also colloquially referred to as licence fees.

EASY-LIZE is the portal for packaging licensing of the dual system EKO-PUNKT.

Proof of disposal

A waste disposal certificate is an important document in waste management. It documents that waste has been disposed of properly and in accordance with the law. In the event of problems or complaints, the disposal process can be traced to determine who was responsible for the disposal and whether it was done correctly. The certificate is usually issued by a waste disposal or waste management company.

A certificate of disposal is required by law, particularly for the disposal of hazardous waste. However, it may also be required for the disposal of non-hazardous waste. The exact requirements depend on the type and quantity of waste and the applicable regulations.

A waste disposal certificate contains all the important information about the disposal process. This includes information about the waste generator, the disposal company, the type and quantity of waste disposed of, and the time and place of disposal. The document is signed by both parties and filed.

No proof of disposal is required for dual system packaging disposal. The Central Packaging Register Office (ZSVR) confirms the correct execution to the dual systems, which must provide the corresponding proof.

Packaging material

Packaging material includes all materials from which packaging is made. This includes, for example, plastics, paper, cardboard, metals, glass or wood. Packaging material is used to protect, transport or present products.

The choice of packaging material depends on various factors, such as the product to be packaged, the storage and the transport route.

Packaging material is subject to specific regulations in many countries to minimise the impact on the environment. For example, recycling and reuse requirements may be mandated, as well as minimum recyclability requirements for packaging. To comply with these requirements, manufacturers and distributors must ensure that they use packaging materials that meet the requirements of the country in question.

Overall, the packaging material is an important factor in the packaging of products and has an impact on the functionality, environmental impact and economic viability of the packaging. It is therefore of great importance to carefully consider the choice of packaging material and to comply with the relevant regulations.


Recyclate is a term used in the recycling industry and in packaging recovery. It refers to a material that is produced from recycled waste and can be used as a raw material for the production of new products. Post consumer recyclates are based on packaging waste from the dual system.

A well-known example of a recyclate is PET. PET bottles can be collected after use, cleaned and processed into so-called R-PET. This recyclate can then be used to make new PET bottles or other products.

Recyclates are kinder to the environment than raw materials from primary, mostly fossil sources. They help to conserve resources and reduce CO2 emissions. In addition, they promote the circular economy because they are made from waste materials.

The use of recyclates is also an important aspect of packaging licensing. In many countries, companies that put packaging on the market have to achieve certain recycling rates and increase the use of recyclates in order to fulfil their environmental responsibilities.

More information on the topic of raw material cycles and recyclate supply can be found in EKO-PUNKT's Packaging Competence Centre.

Packaging Register (Verpackungsregister)

The Packaging Register is a central data collection managed by the Central Packaging Register Foundation (Stiftung Zentrale Stelle Verpackungsregister, ZSVR). It was introduced as part of the implementation of the Packaging Ordinance and serves to collect data on packaging and to monitor compliance with the Packaging Act.

Companies that put packaging into circulation must register in the Packaging Register and provide information on their packaging. This includes, for example, information on the type of material, quantity and disposal of the packaging. Registration in the Packaging Register ensures that companies comply with their obligations under the Packaging Act.

The packaging register is also intended to contribute to better recycling and reuse of packaging waste. The data collected enables better planning and control of the disposal and recycling of packaging waste. In addition, the packaging register creates greater transparency as the data is publicly accessible. In case of non-compliance or infringements, the ZSVR can impose fines.

Place on the market "Inverkehrbringen"

"Placing on the market" ("Inverkehrbringen") refers to the sale or making available of a product to the consumer market. When a company manufactures a product and places it on the market, it is considered to be placed on the market. This includes packaging, as it is an integral part of the product.

In terms of packaging licensing, placing packaging on the market comes with certain obligations. Manufacturers and distributors of packaging must ensure that their packaging meets the legal requirements and is licensed accordingly. It is important to ensure that packaging is safe for use by the end consumer and fulfills its function.

Compliance with packaging marketing regulations is critical to sustainable and environmentally friendly waste management. Companies must ensure that their packaging subject to system participation is licensed to ensure that it can be properly disposed of and recycled after it has been placed on the market.

Sales packaging

Sales packaging is packaging that serves to protect a product and at the same time facilitate its sale and transport. It is the packaging that the end consumer sees and opens when buying a product. Sales packaging comes in different sizes and shapes, depending on the type of product and the way it is sold. They can be made of different materials such as cardboard, plastic or metal.

Sales packaging must meet certain requirements to protect the contents and inform the customer. This includes, for example, information on the quantity of contents, best-before date and list of ingredients. Safety instructions and warnings must also be placed on the packaging if, for example, the product contains hazardous chemicals or is unsuitable for children.

In Germany, sales packaging is subject to the Packaging Act and must participate in a dual system, such as EKO-PUNKT. This system participation ensures that the packaging can be recycled at the end of its life cycle and thus contributes to protecting the environment.


Still questions about packaging licensing? Here are a few more answers to find

Is there a difference between packaging licensing and system participation in the Dual System?

No, both mean the same thing. They are merely different formulations. "Packaging licensing" is the common term, "system participation" is the official legal term.

Why is packaging licensing important in general?

Packaging licensing makes a relevant contribution to sustainability because your financial contribution ultimately ensures that packaging or its recyclable materials can be recycled. The licensing fees ensure that the dual systems can provide the structures necessary for recycling. This means collection, sorting and recycling. Packaging is one of the most common types of waste in Germany. And the trend is still rising. Moreover, the production of packaging requires large quantities of primary raw materials - for example, oil in the case of plastic packaging. For this reason alone, it is sustainable to use packaging disposed of by the end consumer to produce recycled raw materials. This makes a significant contribution not only to the conservation of primary raw materials, but also to CO2 reduction and thus to climate protection.

What is the meaning of the different terms "service packaging", "sales packaging", "shipping packaging" etc.?

In principle, these distinctions are superfluous with regard to packaging licensing. This is because, according to the latest Packaging Act, all packaging that is placed on the market for the first time and can end up at the end consumer must be licensed in principle. Only transport packaging that is used, for example, to supply wholesalers and therefore does not reach the end consumer is exempt from the licensing obligation.

What does "Erstinverkehrbringer" (first distributor) mean in relation to packaging?

"Erstinverkehrbringer" (first distributer) is a term from the Packaging Act. It refers to natural or legal persons who put a packaging product or packaged goods into circulation on the German market for the first time. If you take on this role from the perspective of the law, you are responsible for complying with the regulations of the Packaging Act. This means, among other things, that the packaging is fed into the dual system and that you carry out the packaging licensing for this purpose.

This means that you, as the initial distributor in Germany, pay a participation fee (licence fee) to a dual system. This money is used to finance the disposal of packaging waste generated in households or comparable sources. These include accommodation establishments, canteens, large kitchens, bakeries as well as craft and forestry businesses.

The capacity as first distributor can fall to various market actors such as manufacturers, importers or traders. It does not matter which products you trade in. For example, if you operate an online shop for ceramics and send your goods in shipping packaging, you may also become a first distributor. The prerequisite is that it is packaging that has not yet been placed on the German market.

Who is an end consumer according to the Packaging Act?

The Packaging Act stipulates that all packaging that typically accumulates at private end consumers must be licensed. However, establishments that are not directly associated with the term "end consumer" are also considered to be private end consumers. Restaurants and canteens, for example.

What happens if I do not comply with my system participation obligation in the dual system?

In such a case, you will face severe fines of up to six figures. In addition, you will be prohibited from selling products in unlicensed packaging. You should avoid both of these at all costs, even as a small business, because it can quickly threaten your existence. Especially since participation in a dual system definitely doesn't cost the earth. Especially smaller online shops or companies of a similar size have an annual financial outlay of well under 100 euros.

What is the role of the Central Packaging Register (ZSVR)?

The Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR) is something like the regulatory office for packaging licensing. It checks that everyone who is obliged to participate in the dual system actually complies with this obligation. The whole thing is done with a maximum of transparency. All companies registered with the ZSVR can be viewed publicly on the LUCID portal. Ultimately, this ensures fair competition.

What is LUCID?

LUCID is a database established by the foundation "Zentrale Stelle Verpackungsregister" (Central Agency Packaging Register – ZSVR). If you produce packaging, trade with it or sell packaged products, your company must register with LUCID and deposit the packaging license information. In this way, LUCID plays a key role in enabling the ZSVR and the Umweltbundesamt (Federal Environmental Office Germany) to monitor whether companies are complying with the Packaging Act.

For private end consumers, LUCID only plays an indirect role. They can check in the publicly viewable directory whether a (packaging) producer, importer or distributor is properly registered.

Who does the packaging law apply to?

The Packaging Act applies in principle to manufacturers. However, the definition of manufacturer in the law is broad and also includes actors who are not directly involved in the manufacturing process of the packaging. On the one hand, producers of packaging must comply with the law. On the other hand, the Packaging Act affects your company if you fill packaging with goods and place them on the market for the first time with commercial intentions, i.e. if you are a trading company or online retailer. The commercial purpose includes not only the sale to your customers, but also sales promotion measures such as free samples.

If you import goods that are already pre-packaged, the Packaging Act also applies. The decisive factor is that your packaging ultimately accumulates as waste at the end consumer or comparable points. Bakeries, large-scale catering establishments and canteens, as well as craft and forestry enterprises are considered comparable sources of waste. From the point of view of the law, they are on an equal footing with private households, so that you must license your packaging and declare the quantities delivered to LUCID if businesses of the aforementioned types are among your customers.

The Packaging Act does not only apply to companies that are based in Germany. If your company is located abroad and you want to place packaging on the German market, you must carry out packaging licensing just like your German colleagues.

When do I need a packaging license?

If you are one of the producers according to the definition in the Packaging Act, you must carry out packaging licensing and register in the "LUCID" register with the relevant data. This therefore means that you must register if you are a packaging producer or deal in packaged goods as a trader, importer or mail order/online retailer.

If you produce or sell service packaging that is filled with goods by your commercial customers in close proximity to the point of sale, you may also need a packaging license. Your customer has the option of outsourcing the packaging licensing obligation to you as an upstream economic stage. In this context, the law refers to a pre-share.

What does the packaging law mean?

The law means, among other things, an obligation for initial distributors to license packaging. It was passed with the intention of making companies responsible for packaging in terms of product stewardship. The aim is for you, as a packaging manufacturer, to address in advance how your product can be disposed of at the end of its life cycle.

What is meant by the dual system?

The dual system dates back to the 1990s, when separation into household waste and recyclable raw materials such as paper, glass and plastic was introduced in Germany. While public waste management companies continue to be responsible for household waste, private-sector companies take over disposal and recycling of the remaining (packaging) waste. The system thus consists of two players, which is why it is referred to as "dual". As a distributor or manufacturer of packaging, you can choose for yourself which provider from the dual system you want to work with.

Welche dualen Systeme gibt es in Deutschland?

There are currently a total of twelve dual systems in Germany. You can cooperate with one of the following providers:

  • EKO-PUNKT GmbH & CO. KG / Easy-Lize
  • Landbell AG für Rückhol-Systeme
  • Noventiz Dual GmbH
  • PreZero Dual GmbH
  • Reclay Systems GmbH
  • Recycling Dual GmbH
  • Veolia Umweltservice Dual GmbH
  • Zentek GmbH & Co. KG
Which packaging is affected by the Packaging Act?

The Packaging Act distinguishes between packaging that is subject to system participation and packaging that is not subject to system participation. The first category includes:

  • Sales packaging
  • Service packaging
  • Shipping packaging
  • Outer packaging that bundles several products into one sales unit

For these products, as the initial distributor, you must go through packaging licensing. However, as of July 1, 2022, you must also declare in LUCID the quantities of packaging you put into circulation that are not subject to system participation. This concerns:

  • Transport packaging
  • Reusable packaging
  • Deposit-liable one-way beverage bottles
  • Sales and outer packaging that is not generated as waste in private households
  • Packaging of products containing harmful substances

For single-use plastic beverage bottles, the Packaging Act also stipulates that they must be made of at least 25 percent recyclate from Jan. 1, 2025, and at least 30 percent from Jan. 1, 2030. Single-use glass or metal beverage containers are not affected by this requirement.

Who is obliged to take back transport packaging?

If your company uses transport packaging to ship your goods to business customers, you must take it back and recycle or dispose of it properly.


Where can I license my packaging?

You can do the licensing online right here at EASY-LIZE. This only takes a few minutes and gives you the certainty that you are legally protected and comply with the legal requirements.

How much does packaging licensing in Germany cost?

The price of your license depends on the total weight of the packaging you put into circulation. On the other hand, the raw material or packaging fraction (the material) plays a role. The cost is calculated based on the amount of packaging in kilograms, with different prices depending on the material. You can choose between paper/cardboard, ferrous metals, plastics and other materials, thus specifying exactly what the packaging is made of.

Why is the Grüner Punkt becoming less and less common?

In the early days of the Dual System, Der Grüne Punkt was the monopolist in the household packaging disposal sector. Since the market was opened up to other providers, the Green Dot brand has lost importance. Since 2009, the Green Dot mark as a sign of system participation on packaging is no longer obligatory and in some countries it is no longer allowed due to the possibility of misleading, because the trademark Der Grüne Punkt is not a sign of quality for environmentally friendly packaging but merely a sign that the user makes payments to the company Der Grüne Punkt.

Therefore, if the well-known symbol of this trademark is printed on a packaging, it only means that the producer cooperates with the company "Der Grüne Punkt" and pays a fee for the use of the trademark.  However, this does not mean that disposal is particularly environmentally friendly. Nowadays, there are enough other providers in the dual system, such as EKO-PUNKT, so that you as an entrepreneur can choose the best offer.

What is the Eco Modulation Fee?

The Eco Modulation Fee is an instrument of national and European circular economy policy designed to create financial incentives to make packaging as recycling-friendly as possible and to promote the use of secondary raw materials and renewable raw materials.

The Eco Modulation Fee is paid by the distributors of sales packaging and is dependent on the recyclability of the packaging. The amount of the payment is determined by the national authorities.

In Germany, this will most likely take the form of a fee that will be paid into a fund to be set up. Even if the organisation, threshold values and amount of these surcharges have not yet been decided politically, the EKO-PUNKT PackLab already allows you to simulate the additional costs for packaging with reduced recyclability.

This means that distributors, manufacturers and importers already have an overview of future additional costs and can react at an early stage and take this factor into account in packaging management and packaging development.

All questions answered? Then license conveniently online with EASY-LIZE here now

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