Registration Obligation for All Packaging

Starting July 1, 2022, an extended registration obligation will apply, which will come into force with the amendment to the Packaging Act: by this date, all traders who commercially place packaged goods on the German market will have to register in the LUCID packaging register – regardless of the respective packaging.

This also affects packaging that is not required to participate in the system, such as transport packaging or reusable packaging, for which there was previously no registration requirement. As of July 1, the amended Packaging Act will impose a ban on the sale of packaged goods by all non-registered distributors. These unregistered ones may include many small companies that wrap to-go drinks and sell meals in pizza boxes, disposable cups, bags or butcher’s foil at the point of sale. Delinquent online retailers, especially foreign ones, have been far more significant to date. E-commerce platforms such as Amazon and Ebay will in future only be allowed to accept partners registered in Lucid. “Tens of thousands of registrations from China alone show that the dismantling of competitive distortions has had a good start,” the packaging registry explained in a press release.

“Many mail-order companies have so far ignored the fact that they have to pay to recycle their packaging. The new registration obligation increases the pressure to meet their product responsibility,” says ZSVR board member Gunda Rachut. In the future, electronic marketplaces will have to monitor whether online retailers selling their goods on their platforms are complying with the obligations. If the traders violate the legal requirements, the marketplaces will no longer be permitted to allow them to sell their goods.

The ZSVR estimates the number of those affected at “several hundred thousand,” Rachut said last week during the Munich environmental trade fair Ifat. Rachut is critical of the fact that plastic packaging that can be recycled well is increasingly being substituted by paper-plastic composites that are difficult or impossible to recycle. The ZSVR and the Federal Environment Agency want to take this into account with a new version of the “Minimal Standard for the Assessment of Recyclability”.

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