
The amendment to the Packaging Act will affect online retailers in particular. From 1 July 2022, they will also be required to register their packaging. The registration process will start on 5 May 2022, giving retailers time to prepare for the necessary changes.
Online retailers primarily place shipping and sales packaging on the market with their goods. This typically accumulates as waste with private end consumers. Whoever sells such packaging has Obligations under packaging law to fulfil: Specifically, retailers must register in the LUCID packaging register and pay for the disposal and recycling of their packaging.
The fact that online retailers have to fulfil these obligations is nothing new. If retailers fail to comply with the law, they could face fines. What is new from 1 July 2022 is an extended registration obligation, which was introduced with the amendment to the Packaging Act comes into force: By this time, the register all retailers who place packaged goods on the German market on a commercial basis in the LUCID packaging register - regardless of the respective packaging.
This also affects so-called packaging without a system participation obligation, such as transport or reusable packaging, for which there was previously no registration obligation. There is a need for action for online retailers: In addition to shipping, sales and/or secondary packaging, do you also sell Packaging without system participation obligationthey must extend their existing registration in the LUCID Packaging Register to include information on the additional packaging (change registration).
The new registration process will start on 5 May 2022, giving the affected online retailers enough time to comply with the law. However, they do not have to conclude a contract with a system for packaging that is not subject to system participation, nor do they have to specify the packaging quantities.
Changes for marketplaces and fulfilment service providers
Do online retailers sell their packaged goods on electronic marketplaces, they will be subject to stricter controls from July 2022 at the latestMarketplaces have new direct inspection obligations and must check that their online retailers fulfil the legal packaging obligations. If the sellers on the platforms violate the legal provisions, the marketplaces may no longer allow them to sell the goods.
The Central Agency Packaging Register (ZSVR) provides marketplaces with an interface for automated register retrieval. This allows them to check the registration of traders on a daily basis.
Not only for electronic marketplaces, but also for Fulfilment service providers are subject to new inspection obligations: From July 2022, they must also ensure that their clients behave in a legally compliant manner. In future, they will no longer be allowed to offer their services to customers who violate the Packaging Act.
Further news on the Packaging Act


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