The Packaging Ordinance in Germany - a guidebook.

Guide to the new packaging ordinance


What do online retailers need to consider?

The Packaging Ordinance is a legal regulation in Germany that determines how packaging should be designed and used. As more goods are produced, shipped, and consumed, the amount of packaging waste increases. To address this issue, the German legislature established the Packaging Ordinance in 1991, which was replaced by the Packaging Act in 2019. But what do these legal requirements mean for your company? And what do you need to consider when packaging your goods?

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Packaging Ordinance - Definition and Examples

The Packaging Ordinance was adopted in Germany in 1991 to regulate companies' responsibility for the disposal of their packaging. The aim was to reduce the amount of packaging waste. By partially transferring the responsibility to the economy, it was in the companies' best interest to reduce their use of packaging or opt for recyclable solutions.

What is regulated by the Packaging Ordinance?

The Packaging Ordinance for Germany contains various provisions that apply to all aspects of packaging. These include:

  • Materials: The Packaging Ordinance regulates which materials may be used for packaging and which may not. For example, certain toxic or environmentally hazardous substances must not be present in packaging.
  • Size and weight: The Packaging Ordinance stipulates that packaging should generally be designed to be as small and light as possible to reduce packaging waste.
  • Labeling: Packaging must indicate its composition according to the Packaging Ordinance. This is intended to facilitate recycling, reuse, or disposal. These labels include, for example, a recycling symbol that indicates the materials from which the packaging is made and how it can be recycled.
  • Reuse: The Packaging Ordinance requires packaging to be designed for reuse as often as possible.
  • Recovery and disposal: The Packaging Ordinance regulates how packaging should be recovered or disposed of. This includes, for example, the obligation to take back packaging offered by manufacturers or retailers.


Types of packaging according to the Packaging Ordinance

The Packaging Ordinance distinguishes between three different types of packaging:

Sales packaging - Sales packaging is intended for the end consumer. It serves to protect and present the product and can be made of various materials such as paper, cardboard, plastic, or glass. Sales packaging is part of the Packaging Ordinance and is subject to specific regulations regarding materials, size, weight, and labeling of packaging. There are also special regulations for sales packaging that contains food. These include, for example, hygiene regulations and the requirement for nutritional labeling. Sales packaging must be designed for reuse or recyclability and must not pose a risk to the environment. Examples of sales packaging include toothpaste tubes or milk cartons.

Secondary packaging - Secondary packaging includes non-essential packaging that serves advertising purposes or facilitates storage. Additionally, it can provide additional protection for goods against damage or contamination. The folding box for a tube of toothpaste is a good example. End consumers can leave these secondary packagings at the store during the purchase. This type of packaging can also be made of various materials such as paper, cardboard, or glass.

Transport packaging - Transport packaging includes shipping cartons that facilitate the transport of goods and protect them. This type of packaging can also be reusable, such as wooden or metal transport boxes. According to the Packaging Ordinance, the responsibility for the disposal of transport packaging lies with the manufacturers, not the consumers. Typically, the transport packaging is disposed of by sales outlets.

The Packaging Act - more than just a new Packaging Ordinance

The previous Packaging Ordinance was replaced in 2019 by the more comprehensive Packaging Act (VerpackG). The goal of the law is to increase the recyclability and recycling rates of packaging while reducing packaging waste. The following principles generally apply:

§ Anyone who commercially introduces filled packaging into circulation in Germany is responsible for ensuring that it is recycled or taken back.

§ Manufacturers and companies that introduce sales packaging into circulation must license it according to the law. Manufacturers of transport or secondary packaging must be registered with the Central Packaging Registry.

§ The Packaging Act also applies to online retailers who sell packaged goods. Unlike before, they must also license shipping and filling materials. However, if the manufacturer has already licensed the product packaging, they do not have to bear this responsibility.

EU Packaging Directive - Are there any differences?

The EU Packaging Directive and the Packaging Ordinance in Germany are two legal regulations that deal with the design and use of packaging. However, there are some differences between the two regulations:

  1. Scope: The EU Packaging Directive is a European regulation that applies to all EU member states. The Packaging Ordinance in Germany, on the other hand, is a national regulation that applies only in Germany.
  2. Content: The EU Packaging Directive contains general provisions for the design and use of packaging in the EU. The Packaging Ordinance in Germany transposes the EU Packaging Directive into national law and therefore contains specific provisions that apply to Germany.
  3. Up-to-dateness: The EU Packaging Directive is regularly updated to adapt it to current requirements. The Packaging Ordinance in Germany must also be regularly updated to remain in line with the EU Packaging Directive.
  4. Implementation: The EU Packaging Directive is implemented by the member states into national law. In Germany, the EU Packaging Directive is implemented through the Packaging Ordinance.

Special regulations of the Packaging Ordinance

The Packaging Ordinance also includes specific regulations for certain types of packaging or packaging materials that pose special requirements regarding design and use due to their characteristics or areas of application. These include, for example, packaging for food.

Packaging containing food must be hygienic according to the Packaging Ordinance and must not contain substances hazardous to health. Furthermore, it must be designed in a way that ensures the safe transport and storage of food while maintaining its quality.

Packaging for dangerous goods is also treated separately. Packaging containing hazardous goods must meet special requirements according to the Packaging Ordinance to ensure safety during transport. This includes special markings and specific materials, among other things.

Packaging for medical devices must also meet special requirements according to the Packaging Ordinance to ensure the safety and quality of the medical devices. Requirements regarding materials and labeling are included in these regulations as well.

Finally, packaging made from harmful materials such as PVC is subject to special regulations according to the Packaging Ordinance. They may only be used in certain cases and must fulfill additional criteria.

Packaging licenses for international online retail

If you ship your goods internationally, you must also consider the legal requirements in the destination country. For example, similar packaging regulations to the Packaging Act in Germany apply in other EU countries.

Packaging licenses are always permits granted by governments or other regulatory authorities for the use of specific packaging materials or methods.

For example, shipping products to certain countries may require the packaging to meet certain safety standards to ensure the integrity of the products during the transportation process. In other cases, packaging licenses may be required to ensure that the packaging is environmentally friendly and complies with waste disposal regulations.

To obtain a packaging license for international online retail, companies typically need to submit an application to the relevant authority and meet the specific requirements. This can vary depending on the country and type of packaging and may also vary from company to company. Therefore, it is important for companies engaged in international online retail to familiarize themselves with the applicable regulations and requirements in the countries they wish to ship to.

Therefore, make sure to ascertain the regulations in the destination country and to what extent you are responsible for disposal. At the European level, it is important to keep track of the development of the EU Packaging Directive and its implementation.

Applying for a packaging license

If you want to apply for a packaging license, various information will be requested, and a number of documents must be submitted:

  • An overview of the company and its activities
  • Information about the planned packaging materials and methods
  • Information about the quality and safety of the packaging
  • Information about the environmental compatibility of the packaging
  • Evidence of compliance with applicable regulations and standards

It is important for companies to carefully compile and submit all necessary information and documents to increase their chances of obtaining a packaging license. The competent authority will then review the application and decide whether to grant the packaging license or not.

It is possible that your company may have to pay fees for obtaining a packaging license. The amount of these fees depends on various factors, such as the type of packaging and the country in which it is intended to be used.

We are here to assist you

The Packaging Act brings challenges, but also new opportunities for online commerce. It helps companies to handle resources responsibly and comply with the applicable regulations internationally. If you need assistance with licensing your packaging, contact our staff at an MBE Center near you. Together, we will clarify the extent to which you need to request packaging licenses and whom you need to contact for this purpose.

You can reach us by phone - without waiting loops and automated messages. We are always personally available. Furthermore, we are represented nationwide at more than 150 locations, including near you.

We look forward to your inquiry!

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