Germany’s new Packaging Law (VerpackG) became effective on January 1, 2019 and replaced the German Packaging Ordinance (VerpackV) . VerpackG establishes a new national authority (Zentrale Stelle), significantly increases targets for material recycling, and adds new registration and data reporting requirements.

Under the new law, manufacturers (i.e., distributors that put packaging into commercial circulation on the German market for the first time) will be required to register with Zentrale Stelle prior to placing the packaging on the market. They also will be required to provide the data listed below, which will be posted on Zentrale Stelle’s Central Packaging Registry.

• Registration number (provided by Zentrale Stelle)
• Material and volume of the packaging put on market
• Name of the packaging scheme contracted by the manufacturer to fulfil its Extended Producer Responsibility
• Duration of the agreement with the recycling company/system

The U.S. Department of Agriculture (USDA) explains in October 31, 2018, FAIRS Annual Country Report on Germanythat, “Depending on the distribution channel, U.S. exporters may or may not be required to contract with a packaging disposal company and register with the Zentrale Stelle.” However, USDA cautions, “even if a U.S. company is not required to register directly, they may be required to share information about material and volume of its packaging by its customers which then include this information in their own reporting to the Zentrale Stelle.”

In addition to increased targets for recycling plastic, paper and paperboard, beverage carton packaging, ferrous metals, aluminum, glass and other composite packaging effective since January 2019, the new packaging law stipulates another increase in recycling targets for these materials that will become effective in 2022.