If you supply to brands that sell in Germany, you will receive packaging data requests — and you will receive them more urgently and more specifically than from clients in most other EU countries. Germany has the most actively enforced EPR system in Europe, with automatic marketplace delisting for non-compliant sellers and a centralised register (LUCID) that any retailer or marketplace can check in real time.
This article explains why Germany is different, what the VerpackG specifically requires that drives data requests to you, and what your German clients are likely to ask for.
Why German clients are particularly demanding
Germany's Verpackungsgesetz (VerpackG) — the Packaging Act — has been in force since January 2019. It requires every company that places packaging on the German market (including foreign brands selling to German consumers) to:
- Register publicly in the LUCID register — a public database maintained by the Zentrale Stelle Verpackungsregister (ZSVR)
- Contract with at least one of Germany's approved dual systems (Der Grüne Punkt, Landbell, Reclay, Interseroh, etc.) to fund household packaging collection
- Submit annual declarations of packaging quantities placed on the market, broken down by material type and packaging category
The LUCID register is public and checked automatically by Amazon.de, eBay, and Otto. Any seller without a valid LUCID number can have their listings suspended without warning. This has created strong commercial pressure on every brand selling in Germany to maintain up-to-date compliance — which requires accurate packaging data from you.
What the VerpackG declaration requires from your data
Germany's declaration is based on tonnage by material category. Your clients submit how many kilograms of each material they placed on the German market in the declaration period (usually the previous calendar year, declared by May of the following year).
The material categories Germany uses align with EU standards, but the dual systems add a layer of specificity. The primary categories your clients must report, and what that means for your BOM data:
| Material category | What it covers | What to specify in your BOM |
|---|---|---|
| Glas (Glass) | All glass packaging | Clear vs coloured — different sorting streams |
| Papier/Pappe/Karton (Paper/card) | All paper-based packaging | Corrugated cardboard, folding boxboard, kraft paper — specify subcategory; Germany distinguishes these for dual system fee calculation |
| Kunststoff (Plastics) | All plastic packaging | Polymer type required — PET, HDPE, LDPE, PP, PS etc.; Germany applies different fee rates per polymer |
| Weißblech / Stahl (Tinplate / Steel) | Steel cans, tins, metal lids | Distinguish from aluminium |
| Aluminium | Aluminium cans, foil, trays | Distinguish from steel |
| Verbundstoffe (Composites) | Multi-material packaging that cannot be separated | Flag as composite; list dominant material — Germany has specific composite categories (Verbund mit Papier, Verbund mit Kunststoff, Verbund mit Metall, etc.) |
| Sonstige (Other) | Wood, ceramics, textiles, natural materials | Rarely relevant for most packaging suppliers |
The corrugated vs non-corrugated distinction
One Germany-specific detail that often causes confusion: the VerpackG and German dual systems distinguish between corrugated cardboard (Wellpappe) and flat/solid board (Pappe/Karton). These have different fee structures in most dual systems.
If your product ships in a corrugated box, classify it as corrugated cardboard — not simply "cardboard" or "Pappe." The distinction affects your client's fee calculation and their dual system reporting. When in doubt, look at the cross-section of the board: if you can see the fluted layer, it is corrugated.
Transport packaging vs household packaging
Germany makes a critical distinction that affects what your clients need to declare:
- Verkaufsverpackungen (sales/household packaging) — any packaging that ends up with a private end consumer. This must be licensed through a dual system. It is what your clients primarily need your data for.
- Umverpackungen (secondary packaging at retail) — grouping packaging used between manufacturer and retailer that does not reach the consumer. Less commonly relevant for e-commerce but applies in B2B supply chains.
- Transportverpackungen (transport packaging) — pallets, stretch wrap, cartons used to transport goods from supplier to retailer or consumer. Does not require dual system licensing but must be taken back from commercial customers.
For most products that reach end consumers, everything — the product box, the inner packaging, the mailer box — counts as Verkaufsverpackungen and must be declared. When providing BOM data, include all packaging components that reach the German consumer, and flag if any component is purely transport packaging.
The Systembeteiligungspflicht: why your data must be complete
The VerpackG requires brands to license 100% of their Verkaufsverpackungen through a dual system. There is no threshold below which they can omit a component. A BOM that omits even a small component — a tissue wrap, a paper insert, an adhesive label — results in an incomplete declaration.
German authorities have audited declarations and identified discrepancies by comparing declared quantities against purchase records and imports. Undeclared packaging can result in fines plus the retroactive licensing fee. This is why German clients will push back on incomplete BOMs — they cannot submit a clean declaration without complete data from you.
The eco-design register: Germany's new layer
Germany introduced an eco-design register alongside LUCID, requiring brands to declare the recyclability of their packaging against defined criteria. This is separate from the dual system licensing obligation.
To assess recyclability, brands may ask you for additional details:
- Whether any plastic packaging includes black carbon-pigmented plastic (poorly detected by NIR sorting equipment — lower recyclability grade)
- Whether adhesive labels on plastic bottles exceed 50% of bottle surface area (affects recyclability)
- Whether any closures are made of a different polymer than the container (affects sorting)
- Presence of hazardous substances or additives in the packaging material
These questions are not yet universally required in BOM data, but German clients increasingly ask them, particularly for plastic packaging. If you can answer them, do — it saves a follow-up.
Practical tips for German client requests
- Always distinguish corrugated from flat board — do not use generic "cardboard"
- Specify polymer type for all plastic components — "plastic" alone is not sufficient for VerpackG reporting
- Flag composite materials explicitly using the German Verbund categories where applicable
- Include all small components: labels, adhesive strips, tissue inserts — Germany requires complete declarations
- Weigh components to the nearest gram — German dual systems calculate fees on exact declared weights
- Version your BOMs with effective dates — German declarations are annual and auditable; your client may need to show which BOM version applied to which year
What happens after you provide the data
Your client takes your BOM data, multiplies it by their German unit sales volume, and arrives at the total tonnage per material category. They submit this to their dual system, pay the licensing fee, and update their LUCID registration accordingly. The LUCID database reflects current compliance, which Amazon and other marketplaces check in real time.
The accuracy of their compliance — and the continuity of their Amazon.de listings — depends directly on the completeness and accuracy of your BOM data.
For the data fields required across all EU markets, see exactly what packaging BOM data your clients need. For material classification specifics, see how to classify packaging materials for EU EPR. For France-specific requirements, read the CITEO supplier guide.