New German Packaging Act

04 JANUARY 2019

The new German Packaging Act took effect on 1 January, replacing the Packaging Ordinance that has been in place since the early 90s. The view was that there were too many free riders and the primary purpose of the new system is to capture every company placing packaging onto the German market through a new Central Registry. For UK companies supplying to Germany through importers, it still the importer's responsibility to register. But for those that supply direct including online sales, they must register too. And registration must be done by the obligated company and cannot be done by a third party. All registered companies must be part of a compliance scheme and pay for the collection of that packaging waste and there is then a requirement for annual declarations for companies above certain tonnage thresholds. 

What is not certain is what jurisdiction the German authorities have over non-German companies supplying direct into the German market and we'll try and find out more. But there are significant fines for non-registration where they have that jurisdiction.

There are a number of useful sources for more information.