Guide · As of: 10 October 2026 · 43 practical questions
Frequently Asked Questions on Packaging Law and Sustainability
LUCID, licensing, PPWR, and environmental advertising – the questions online merchants are really asking. Answered concisely and clearly.
New packaging rules have been in force since August 2026 – and the same questions keep cropping up in merchant forums, marketplace communities, and on our telephone hotline. Here, we provide an initial overview: concise, easy to understand, and without getting bogged down in legal jargon.
The answers serve as general information and do not constitute legal advice. To clarify what applies to your specific situation, it is best to consult your dual system provider or a specialist advisor. As of: 10 October 2026.
The most common misconceptions
- "I don't ship very much." There is no minimum quantity.
- "Small business owners are exempt." Tax rules do not apply here.
- "LUCID is enough." Licensing is required in addition.
- "B2B is exempt." Almost never true for shipping packaging.
- "Since August, I don't need to license anything anymore." That is not correct in such general terms.
- "Compostable packaging belongs in the organic waste bin." No, it goes in the yellow recycling bin.
Does this even apply to me?
Yes. There is no minimum quantity and no de minimis threshold: anyone who packs goods commercially and ships them to customers is generally included – right from the very first parcel. Only private individuals who occasionally sell used items are exempt.
What exactly you need to do depends on your business model. However, a blanket "it doesn't apply to me" is virtually never correct.
No. The small business regulation under tax law (§ 19 UStG) has nothing to do with packaging law. Registration and licensing apply regardless of turnover and company size.
While the EU Packaging Regulation does provide some relief for "micro-enterprises" (fewer than 10 employees and a maximum of €2 million in annual turnover or balance sheet total), this primarily concerns who prepares the technical documentation for packaging featuring your logo – there is no general exemption from registration and licensing.
As a rule, yes. The Central Agency Packaging Register classifies shipping packaging as "unexceptionally" subject to system participation – even if the parcel is delivered to a business customer. The reason: offices, medical practices, craft businesses, hotels, and restaurants are legally considered "comparable sources of waste generation" and are treated like private households.
The situation may be different for pure transport packaging that only arises in industrial and large-scale commercial sectors, such as palletised goods. Specific take-back obligations apply to these instead of the licensing requirement.
No, these are two separate steps – and both are mandatory:
- LUCID is the free, public packaging register of the Central Agency. You register there with your company and brand names and enter your quantities.
- "Licence" is the colloquial term for system participation: a fee-based contract with a dual system that pays for the collection and recycling of your packaging at the end consumer's location.
Important: The quantities you report to the dual system must also be entered in LUCID – the figures must match.
LUCID and licence: register, report, pay
Yes. Registration and system participation must be in place before the first piece of packaging is circulated. Registration in LUCID is free of charge and can be completed quickly online. Afterwards, you conclude a contract with a dual system and report your estimated annual quantity.
No – but a rough guess isn't enough either. The Central Agency requires that quantities are determined based on verifiable data: using data sheets or weighing, not through free estimation. In practice, this works as follows:
- Determine the weight per packaging type (e.g. "cardboard box size M = 180 g") – from the data sheet or by weighing it yourself once.
- Multiply by the number of units purchased or shipped.
- Add packing tape, filling material, and labels.
- Keep the invoice – it serves as your proof.
You don't need to know precisely. You report an estimated quantity at the beginning, ideally based on the previous year. After the end of the year, you report the actual quantity, and final billing takes place. If you ship significantly more than planned during the year, you must submit an update: first to the dual system, then in LUCID.
That depends on the material and quantity – paper and cardboard are significantly cheaper per kilo than plastic. For small shops with a few hundred kilos of packaging per year, experience shows that costs are usually in the low two to three-digit euro range per year. Many systems have minimum fees and online calculators. Registration in LUCID itself is free.
You decide that yourself. There are several approved systems with different prices and minimum fees – a comparison is well worth it. You can switch depending on your contract, usually at the turn of the year.
Only for larger quantities: from 80 tonnes of glass, 50 tonnes of paper, cardboard and paperboard, or 30 tonnes of another material type (e.g. plastic) in the previous year. Submission by 15 May each year, audited by an expert or auditor. The vast majority of small shops are well below this – however, the Central Agency can request the declaration at any time.
No, there is no obligation to do so. The number is primarily used by marketplaces and fulfilment service providers: Amazon, eBay, Etsy & Co. must check it before selling (see Marketplaces, warnings, fines).
Yes, and preferably today rather than tomorrow. You can register retroactively and report quantities for past years to a dual system as well. This does not automatically mean a fine is off the table – but anyone who submits a late report is in a much better position than someone caught by the Central Agency during an inspection. In that case, you face back payments for previous years and the skimming of profits.
Cardboard boxes, mailing bags, filling material: What applies in everyday operations?
New since 12 August 2026: This is the area that has changed the most. Many answers in forums and older guides still refer to the old Packaging Act and are outdated. It is best to discuss what you need to report yourself with your dual system.
As a rule, yes. Shipping packaging includes everything that arrives with the customer: packing tape, paper cushioning, bubble wrap, air pillows, packing chips, tissue paper and labels. Paper and cardboard fall under “paper, cardboard, paperboard”, while plastic tape and films fall under “plastics”.
As a rule, no. According to the European Commission's guidance documents, erecting, filling, sealing and a standard shipping label do not make you the producer of the packaging. However, labels that you apply yourself are included in your quantity report.
Packaging featuring your own logo may entail additional obligations for you, such as registration, licensing and documentation. Which ones apply depends, among other things, on the size of your company. It is best to clarify this with your dual system or a specialist consultant before placing your first print job.
Yes – that is actually a good idea. However, the used cardboard box is only licence-free if you can clearly prove that it was already part of a dual system previously. With outer packaging from your own deliveries of goods, this is usually not possible because they were transport packaging. You must report new packing tape, filling material and labels in any case. The pragmatic approach: simply report reused cardboard boxes as well.
No. Packaging placed on the market before 12 August 2026 may continue to be used – the European Commission has clarified that such stock does not need to be recalled. Regarding the licence: your existing system participation will run until 31 December 2026 at the latest. Check with your dual system which packaging you will still need to license yourself from 2027 onwards.
PPWR and new Packaging Act: What is new, what is coming?
Two things at once: Since this day, the EU Packaging and Packaging Waste Regulation (PPWR) has applied directly in all EU countries. And in Germany, the Packaging Law Implementation Act (VerpackDG) has replaced the previous Packaging Act.
The basic principle for online retailers remains the same: register (LUCID), license (dual system), report quantities. The three main new points are: who is considered a “manufacturer” of shipping packaging, documentation obligations for packaging manufacturers, and stricter rules for shipping to other EU countries. You can find an overview of all deadlines in our guide PPWR simply explained.
Yes, you should sort out a few things this year:
- Check LUCID data: Existing registrations remain valid. Necessary changes must be entered by 12 November 2026.
- Clarify system contract: Existing system participations run until 31 December 2026 at the latest. Clarify with your dual system how things will proceed from 2027 onwards.
- Check international shipping: Each EU country to which you ship to end customers has its own obligations (see Shipping abroad).
- Check environmental claims: Since 27 September 2026, many environmental claims on packaging have been prohibited (see Sustainability).
Don't act too hastily. All quantities shipped by 11 August 2026 will remain subject to licensing fees and must be accounted for in 2026. Even after that date, in many cases certain items will remain your responsibility, such as packaging for your own products, packaging featuring your logo, imported goods, and any packing tape and filling material added by yourself. Talk to your dual system before cancelling.
The EU declaration of conformity is drawn up by the "producer", meaning the party that manufactures the packaging or has it manufactured under their own name or brand. If you have packaging produced with your logo or package your own products under your name, this may also apply to you.
You can find the documents we provide for our products at id.nordwerk.de.
Yes, that is coming: in future, dispatch, transport and outer packaging must have a maximum of 50% empty space – and filling material counts as empty space. The person packing the parcel is responsible. The rule will apply from 1 January 2030 at the earliest; if the EU sets the calculation method later, three years after that. Product packaging that is sent directly as mailing packaging is exempt, for example.
Our tip: choose cardboard boxes today that fit the goods – this saves filling material, postage and hassle later on. Cardboard boxes with variable height and, for textiles, our Bag Finder are helpful.
Not in Germany at present. Anyone who voluntarily prints material codes must use the official abbreviations (e.g. "20 PAP" for corrugated board). EU-wide uniform pictograms will become mandatory from 12 August 2028 at the earliest – likely later, because the EU has not yet published the detailed rules. France and Italy already have their own mandatory requirements (see Shipping abroad).
No. The Green Dot has not been mandatory for many years and is not proof that your packaging is licensed. It is a registered trademark – you may only print it with a corresponding contract.
Shipping abroad
No. Registration and licensing in Germany only apply to Germany. If you ship directly to end customers in another EU country, you are the "manufacturer" there – for the mailing packaging and for the packaging of your products. This means: registration and system participation in the respective country and, in accordance with the PPWR, additionally a local authorised representative who fulfils your obligations there. Austria has required this authorised representative from foreign mail-order retailers since 2023, and France does too. Many dual systems and specialised service providers offer this as a package.
As things stand today, no. There are proposals: the European Commission wants to suspend the requirement for an authorised representative for companies from the EU until 2035, the European Parliament's Committee on the Environment wants to limit this to small companies, and the German government has proposed an exemption for retailers under 10 tonnes per year. None of this has been decided – negotiations in the Council of Member States were even halted in spring 2026. Until an amendment is published in the Official Journal of the EU, the requirement applies. And even then, registration and licensing in the destination country would remain in place.
For very small quantities abroad, it is therefore worth calculating whether shipping to each individual country is worthwhile.
No. When shipping directly to end customers in another EU country, you are considered the manufacturer there – regardless of where you bought the packaging. Purchasing in the destination country does not replace an authorised representative and registration.
France requires the Triman logo with sorting instructions (Info-tri) for consumer packaging; the French authorities can impose fines for violations. Italy has required environmental labelling since 2023: a material code and, in the case of consumer packaging, disposal instructions – this can also be done digitally, for example via a QR code or on the website. Both labels apply until the EU-wide labelling comes into effect. It is best to have your French system confirm whether the Triman logo is also required for pure mailing packaging.
Marketplaces, cease-and-desist letters, fines
Because they have to. Online marketplaces and fulfilment service providers (e.g. Fulfilment by Amazon) are legally obliged to obtain your registration confirmation and a self-declaration before sale. If this proof is missing, they are not allowed to offer your products or ship for you. For countries like France, the platforms also require the local EPR number.
Do not confuse: Registration with DIVID (Single-Use Plastics Fund at the Federal Environment Agency) is different from LUCID. It only affects certain single-use plastic products, such as to-go food containers, lightweight carrier bags or wet wipes.
Yes. Courts classify the obligations of packaging law as so-called market conduct rules – competitors and associations can therefore issue cease-and-desist letters for violations (e.g. Bonn Regional Court, ruling of 29.07.2020, ref. 1 O 417/19). Good to know from the same ruling: It was sufficient to be registered under the business name under which the shop operated. Make sure that all your brand and shop names are entered in LUCID.
- Fines of up to €200,000 for failing to participate in a system, and up to €100,000 for failing to register
- Sales ban: You are not allowed to offer goods at all without registration and a licence – and marketplaces are required to block listings
- Back payments for previous years and disgorgement of profits
- Cease-and-desist letters from competitors
The Central Agency means business: between 2019 and 2024, it reported around 25,800 suspected cases to the state enforcement authorities. In one published case, an online pharmacy that had failed to participate in a packaging recovery scheme for five years had to make back payments of at least €2 million.
Sustainability and green claims
Not automatically. Life cycle assessments show that the amount of material used is at least as important as the material itself. Paper is recycled more frequently – in 2023, the recycling rate for paper and cardboard packaging in Germany was 86.6%, compared with 52.2% for plastic packaging. On the other hand, plastic often requires significantly less material.
An example from a study by the Federal Logistics Association (2025) for shipping a sweater: paper bag around 11 g CO₂e, plastic bag around 16 g, standard cardboard box around 89 g. The key takeaway: for textiles, a lightweight mailing bag – whether paper or film – has a significantly lower climate impact than a cardboard box.
Recycled material is plastic recovered from waste. It replaces virgin plastic and reduces the climate impact of the material. "Post-consumer recycled material" from used packaging, such as from the yellow recycling bin, is particularly valuable – as it closes the loop. Only this type counts towards future EU recycled content targets.
The Blue Angel eco-label for film products such as mailing bags (DE-UZ 30a) requires at least 80% post-consumer recycled material and limits pollutants. From 2030, plastic packaging will have to contain minimum proportions of recycled material anyway – 35% for most film mailing bags. You can find our mailing bags with the Blue Angel under ECOMAILER®.
Mostly not for mailing bags – and no, they do not belong in the organic waste bin. Only certified organic waste collection bags are allowed there, and even then, only if permitted by your local municipality. Compostable mailing bags belong in the yellow recycling bin or lightweight packaging bin. They are not recycled there, but incinerated. The German Environment Agency therefore sees "no overall ecological advantages" in compostable and bio-based plastic packaging.
"Compostable" is primarily useful where explicitly mandated by the EU – such as for tea bags and coffee pods from 2028 onwards.
Largely no longer permitted when selling to consumers as of 27 September 2026. The amended Act against Unfair Competition (UWG) transposes an EU directive against greenwashing. Since then, the following rules apply:
- General environmental claims such as "eco-friendly", "green", "climate-friendly" or "biodegradable" are only permitted if you can demonstrate recognised, exceptional environmental performance – for example, via the EU Ecolabel or a state-recognised environmental label. In practice, the same applies to "sustainable".
- "Climate-neutral" based on carbon offset payments is prohibited.
- Self-designed eco-labels are prohibited – only labels with independent certification or state-backed marks are permitted.
- There is no sell-off period for packaging that has already been printed. If necessary, the only solution is to cover it up with a label.
What is still permitted: specific, verifiable details directly on the packaging, for example, "box made from 80% recycled fibres" – with the supplier's proof kept on file. Check printouts before printing, and consult your Chamber of Commerce or a lawyer if you are in doubt.
Only if you are authorised to do so and the product is actually certified. The FSC mark requires FSC certification or a licence. The Blue Angel requires a label use agreement with RAL and only applies to products that meet the award criteria. For "OK compost", the certification body is responsible. Clarify the use with your supplier before printing – using a label without authorisation is misleading and infringes trademark rights.
These are material codes. They indicate what the packaging is made of – not whether it is actually recycled:
- 20 PAP = corrugated board, 21 PAP = other cardboard, 22 PAP = paper
- 4 LDPE = low-density polyethylene, typical for mailing bags and films
- 81 C/PAP = composite mainly of paper with plastic, 84 C/PAP = paper with plastic and aluminium
Providing this information is voluntary in Germany. These codes are being phased out in favour of the EU-wide uniform labelling.
- Cardboard boxes, paper mailing bags, paper cushioning: Waste paper – flatten cardboard boxes as much as possible
- Plastic mailing bags, bubble wrap, air cushions, polystyrene chips: Yellow bin, yellow bag or recycling bin
- „Compostable“ mailing bags: likewise the yellow bin – not the organic waste bin
- Paper bags with glued-in bubble wrap: separate if possible, otherwise put in the yellow bin
- Packing tape: can remain on the cardboard box – however, removing it helps recycling
Tip for your customers: do not stuff materials into one another, so take the film out of the cardboard box. Local waste advisory services are familiar with regional specifics.
From an ecological perspective, a reusable mailing bag is only worthwhile after multiple cycles – compared to a lightweight single-use bag, this is around 4 to 7 cycles depending on the study. In practical tests by major retailers, 75 to 81% of the bags were returned, but on average each bag was only used about three times. Reusable packaging is currently more expensive than single-use packaging. For small shops, a precisely fitting, lightweight single-use packaging made of recycled material or recycled paper is often the more realistic lever. The EU reusable quotas from 2030 mainly affect pallets, crates and containers – cardboard boxes are explicitly exempt.
The right size. According to the German Environment Agency (Umweltbundesamt), packaging that is too large is “ecologically disadvantageous in two ways“: more cardboard material and additional filling material. Just 20% less volume saves around 14% in cardboard weight. For textiles, a lightweight mailing bag is usually sufficient instead of a cardboard box. This is followed by: recycled material or recycled paper, mono-material and as little filling material as possible.
How Nordwerk supports you
At id.nordwerk.de, you'll find the documentation we provide for our products—depending on the product, this may include, for example, a technical data sheet or a PPWR certification.
For products for which we have issued a PPWR confirmation or an EU Declaration of Conformity, you can find the document at id.nordwerk.de. Good to know: Many factors are only determined during use—such as empty space, licensing, or labelling requirements in the destination country. PPWR-compliant” is therefore not a characteristic that empty packaging possesses on its own.
You can view your orders with items and quantities in your customer account and on your invoices. Material specifications can be found in the item's technical data sheet. This allows you to determine your quantities yourself, as described under LUCID and licensing.
Your question was not included?
Our team is happy to help you – Monday to Thursday 08:00–17:00, Fridays 08:00–15:00.
Sources: Central Agency Packaging Register: Mail order and e-commerce · EU Commission: FAQ on PPWR (August 2026) · Regulation (EU) 2025/40 (EUR-Lex) · VerpackDG (Packaging Act), Federal Law Gazette (BGBl.) 2026 I No. 207 · Third Act Amending the Act Against Unfair Competition (UWG), BGBl. 2026 I No. 43 · German Environment Agency: Shipping packaging · German Environment Agency: Packaging waste · BVL: Sustainable design of packaging in e-commerce (2025) · Consumer Advice Centre: Organic waste bin · Regional Court (LG) of Bonn, 1 O 417/19 · Central Agency: Case reports
As of: 10 October 2026. This page serves for general information purposes and does not constitute legal advice. Your specific obligations depend on your business model.
