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Notice 33 – German Packaging Register

22nd July 2019


The German-British Chamber of Industry & Commerce warns that the newly created German Packaging Register (ZSVR) has passed on some 2,000 discrepancies in reported packaging data to the relevant German authorities for legal enforcement. Affected companies can expect severe financial penalties for the breaches. The Chamber therefore advises British companies to check their German packaging obligations and license their packaging if necessary.

The new Register has been operating since January this year and since then companies have been legally obliged to report their packaging data to both their chosen recycling scheme and the Register. The Register analyses this data and passes on discrepancies for legal enforcement.

Germany’s packaging law covers sales, product, shipping and service packaging. It differs from UK regulations in a variety of ways:

  • As of this year there are no more minimum thresholds – meaning internet sellers sending one parcel are also covered by the law.
  • The first one to introduce sales packaging to the German market commercially is responsible for licensing it – it is not necessary to have a German business presence and it doesn’t matter if the goods are sold via distributors, retailers or directly to end-users.
  • End-users can be private households but also businesses and institutions. Ultimately, if the packaging is included in the Register’s catalogue of packaging that is ‘typically discarded by the end-user’, it needs to be licensed.

To be legally compliant, British companies need to sign up with the Register and join a German recycling scheme, which will license the packaging for a fee.

The German-British Chamber offers a Recycling Consultancy Service which helps British companies fulfill their legal obligations under the Packaging Law.

For more information on this service and about recycling obligations in Germany, please contact Jana Toon, Tel: +44 (0)20 7976 4188 or email: