by Renee

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E-commerce seller in Germany? All about VerpackG

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Soon it will be mandatory according to the Packaging Act VerpackG (VerpackungsGesetz) to have an EPR registration. This applies if you sell through Amazon Germany, and effective July 1, 2022. Are you an e-commerce entrepreneur through Amazon Germany, and do you use cardboard packaging? If so, you must complete your registration by July 1. If you don’t, Amazon will take your products offline or you could face hefty fines. Note! Do you sell through another marketplace, such as Zalando.de, and have stock in Germany? Then you are also required to register. Amazon wants to make EPR registration mandatory in France as well, but not yet in such a short time. Therefore, this blog will mainly focus on German EPR registration. In this blog, we’ll tell you what a VerpackG entails, who needs it and how to arrange it!

What exactly does VerpackG entail?

The Extended Producer Responsibility (EPR) registration is part of a renewed environmental policy by Amazon. It ensures that you as a salesperson are responsible for the entire life cycle of the products you sell. This includes disposal of packaging materials! It applies to vendors who use packaging for their products.

The purpose of registration is to make vendors who put packaging into circulation also responsible for the additional costs involved, such as the cost of recycling packaging materials. The new scheme, or VerpackG (VerpackungsGesetz), is the second variant of an older regulation that ensures proper disposal of packaging. This was formerly the VerpackV (VerpackungsVerordnung). This predecessor has been around for a while and did not take into account the massive online sales of products, and thus packaging handling. So VerpackG is the modernized version, which does take this into account.

In Germany, EPR registration is also going to become mandatory for electronic devices and batteries, this is going to be from Jan. 1, 2023. However, that is still a little further away; for now, the EPR registration for packaging is most important!

Who should consider VerpackG?

First it was that you needed an EPR registration if you had stock in Germany at all, but now Amazon is also adopting these rules. So if you sell via Amazon.de to German consumers and use packaging around your products (who doesn’t?) then as of July 1, you will be required to have a registration and make an annual declaration of the amount of packaging you have put into circulation in Germany. For example, your products may be wrapped in plastic or cardboard.

VerpackG refers to both primary and secondary packaging: that is, both the packaging in which the product itself is packed and the shipping packaging. For example, a phone is packed in a small box, which is then put into a larger box for shipping. Kind of neat right?

If you have already taken care of your EPR registration in Germany, then all you have to do is indicate to Amazon what your EPR number is. The numbers and registrations are maintained in the LUCID register, and can be found on the ZSVR (Zentrale Stelle Verpackungs Register) website.

VerpackG

How do I arrange an EPR registration?

There are a few options to properly register for the VerpackG packaging law. A few are listed below:

  • If you don’t already have an EPR number, you can apply for one through the ZSVR (Zentrale Stelle Verpackungs Register) website and go through the registration yourself, without outside help.
  • You can also choose EPR services as a seller on Amazon. If you choose this, you will receive guidance on registration and reporting from an EPR services provider. Applications can be made through this link
  • We can also handle your EPR registration. You can schedule a call through this link; an EPR specialist will give you free, tailored advice on what EPR services you need. From there, you can let us take the wheel.

Dual systems and waste processors

What you should think about is to also register with a dual system: to this you can outsource the mandatory administration and recycling of materials. Because it is inconvenient (impossible even) to retrieve all your packaging from customers yourself. That’s why you contract with a dual party. On this page of the ZSVR, under section 8.2, you will find an overview of current dual systems.

Whichever waste management company you choose, the principle is pretty much the same with all of them. For each type of packaging, consumption is passed on. This is done in kilograms. Every year you must report what your exact consumption by packaging material was. Failure to do so risks fines of up to 200,000 euros or even an export ban. You declare this to both the ZSVR and the waste processor, and pay at the waste processor.

Need help with VerpackG?

Do you have questions about how to arrange your VerpackG registration, or would you rather hand it over? We are happy to tell you how it is, and can also arrange registration for you right away. Through this link you can request advice and/or registration!

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Yonis Brander

VAT consultant

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