In December 2018, many cross-border e-commerce seller had received Amazon’s warning letter about the German New Packaging Act, requiring all sellers to comply with all laws and regulations including the German New Packaging Act. Amazon strongly recommends that all sellers complete the implementation of the new German packaging law before January 1, 2019, otherwise it will not be possible to store or sell goods in Germany.
Three years later, a large number of sellers have received warning emails from Amazon, requesting to upload relevant documents for German packaging regulation compliance, otherwise they will be subject to restrictions of product listing on the platform. Amazon’s stricter product compliance have caught sellers by surprise. How can sellers take actions in product compliance with the German packaging law? How much does it cost to register for the German packaging law in general? Today we explain more about the German packaging law compliance in details.
Which sellers must register for German packaging law?
- Product manufacturer
Usually, the product manufacturer is the first supplier in Germany and is therefore obliged to register.
- The importer of the product
However, if the manufacturer’s headquarters are located abroad, the domestic importer can also be regarded as Germany’s first distributor and therefore as the manufacturer. In principle, in the case of import, the person who is legally responsible for the goods is obliged to participate in the system during transit. In addition, if the obligation is not fulfilled, the distributor will eventually be bound by the distribution ban.
- Mail order company
Similarly, mail order companies are also manufacturers in the sense of VerpackG(German packaging law). The mail order company fills freight containers with goods for the first time, so the system participation and registration obligations of the packaging are always with him, at least for the first container carrier in the sense of the German packaging law. The fact that the delivery package is used to deliver the product to the end consumer always makes it a sales package because it is usually a waste of the end user.
What are the requirements of the German packaging law?
In accordance with the legal requirements of the German Packaging Law, the manufacturer, distributor, or importer of the packed or packaged product shall bear the disposal cost to bear the responsibility for the product and its return and disposal. To achieve this goal, an approved dual system has been established that coordinates collection and disposal and provides permits for the corresponding packaging.
What is the registration process for the German packaging law?
- Importers register online in the LUCID central database before entering the market;
- Participate in the signing of the contract with the system company after obtaining the registration number;
- Fill in the data signed with the system company into the LUCID central database;
- Data check and comparison.
What documents are required to register for the new German packaging law? How to register for the German packaging law?
- Registration requires the following information:
- Company address;
- Sales tax identification number (VAT number);
- National identification number;
- List all brand names, and carry out commercial packaging in the market according to system participation requirements.
- Report the following data
- Registration number (previously provided by “Zentrale Stelle”);
- Packaging materials and volume put on the market;
- The name of the packaging plan signed by the manufacturer to fulfill its extended producer responsibility;
- The period for signing the contract with the packaging plan has been agreed on.
How much is the registration fee for the German Product Packaging Law?
The new German packaging law charges are calculated based on the weight of the packaging material. Currently, the PPK option is selected for the packaging of cartons. According to monthly calculations, if the package weight is less than 780kg, the minimum charge is 11.67€/month, and the minimum requirement for a year is 140€. Interested sellers are welcome to contact us for consultation.