New German Packaging Law: Without registration no commercialization!

On 1 January 2019, the new GPA German Packaging Act (VerpackG) enters into force, replacing the German Packaging Regulation from 1998 (VerpackV). The GPA obliges more producers and distributors – including online retailers – to register on the online database of the newly established Zentrale Stelle (Central Packaging Registry), subject to the supervision of the German Federal Environmental Agency, and participate in a disposal and recycling system.
Without proper registration, producers or retailers must not offer the packaging – nor therefore the products contained therein – for sale in Germany, including via e-commerce. Moreover, the authorities may impose fines up to 200.000 euro on producers and retailers, including importers. Packaging items that require registration and licensing under the new GPA are sales packaging (“Verkaufsverpackungen”) and secondary packaging or outer packaging. The current legal minimum recycling targets have been increased in all material categories. The quotas of the new packaging law provide for an increase in two steps, initially from 2019 and in the second step from 2022.