Mandatory registration as of 1 July 2022 due to expansion of German packaging legislation

June 8, 2022
Royal FloraHolland
Logistics & transport
On 1 July 2022, the Packaging Act VerpackG will be further expanded in Germany. As of this date, anyone who brings products into the German market in sales packaging and/or transport packaging will be required to register with the LUCID Packaging Register. For sales packaging, a contract with a recycling company is also required. In addition, as of 1 July, market places (including Veiling Rhein-Maas) are obliged to check whether suppliers comply with VerpackG. To avoid fines or exclusion from sales, ensure that the necessary actions are taken in good time. Read the important information below and what this expansion of the law means for you.
Do you supply to Veiling Rhein-Maas? Then the Packaging Act VerpackG applies to you and you will need a LUCID registration number to deliver to Veiling Rhein-Maas. From 1 July 2022 onwards, Veiling Rhein-Maas, as a German marketplace, is obliged to check whether suppliers who sell products via their marketplace comply with this Packaging Act. Veiling Rhein-Maas will check whether you are registered with the LUCID Packaging Register of Stiftung Zentrale Stelle Verpackungsregister and under which LUCID registration number. Products from unregistered suppliers may no longer be sold on the Veiling Rhein-Maas marketplace as of 1 July.

Step-by-step plan for compulsory registration due to expansion of VerpackG as of 1 July 2022

Due to the expansion, the Packaging Act now also applies to ‘Business to Business’ transport packaging and not just to 'Business to Consumer' packaging. This means a number of actions are required of you, which we explain below in a step-by-step plan.

Explanation of terms ‘transport packaging’ and ‘sales packaging’:
Type of packagingAlso referred to assAbbreviatedExample of packaging
Transport packaging'Business to Business' packagingB2Bincluding trays, buckets ands boxes
Sales packaging'Business to Consumer' packagingB2Cincluding sleeves, labels and plant pots (to be removes before use)
Step 1: Registration with the LUCID Packaging Register of the Stiftung Zentrale Stelle Verpackungsregister

The LUCID-Packaging Register is an online public packaging register in which all companies that bring packaging (B2C and/or B2B) into the German market must be registered. This was already mandatory for B2C packaging, but from 1 July 2022 it will also be mandatory for B2B packaging. Do you bring packaging directly into the German market? Then you need a LUCID registration number.

The registration process takes about 15 minutes. To make this registration easier for you, a short user manual is available. Registration is free of charge.
Step 1b: Adding B2B transport packaging registration to the LUCID-Packaging Register

Do you already have a LUCID Registration number? An additional action from your side might still be necessary. Do you bring not only B2C sales packaging but also B2B transport packaging into circulation in the German market? Then log on to the LUCID Packaging Register before July 1st to indicate that you use transport packaging to supply Germany and which type this is. You will also find below a step-by-step guide which will help you through this process.
Step 2: Conclude a contract with a recycling company for B2C sales packaging

Another long-standing obligation is to conclude a contract with a recycling company for the volume of B2C sales packaging that you bring into the German market. There are costs associated with this. By doing so, you contribute to the recycling of the packaging material that you bring into the German market. This obligation applies both if you deliver to Veiling Rhein-Maas and/or sell directly to a German customer. Royal FloraHolland has made arrangements with Landbell, one of the biggest recyclers in Germany, which means that they can offer Royal FloraHolland partners favourable rates and conditions.
Step 3: Register your LUCID Registration number (and name of the recycling company) with Royal FloraHolland

As indicated above, Veiling Rhein-Maas has a monitoring task as a marketplace from 1 July. To make this possible, Royal FloraHolland has created extra fields in the 'My Royal FloraHolland' environment, namely 'Change registration packaging law' (within the section 'Company data').

We ask you to register the following data here:
  1. Your LUCID Registration number
  2. The name of the recycling company with which you have concluded a contract

If the above link does not work, you can also go to: My Royal FloraHolland > My profile> Company details > Click on My company.

Important: Only the main user has the rights to make changes in the ‘Company data’ section. And have you already received a LUCID registration number, but not yet concluded a contract with a recycling company? Then log in and add this number. You can always fill in the recycling company later.

We naturally take the privacy laws into account when sharing the necessary information with Veiling Rhein-Maas. We share your personal data only insofar as this is necessary and required for you to continue to participate in the Veiling Rhein-Maas marketplace.

German legislation

For the sake of completeness, we would like to point out that VerpackG is German government legislation and, as such, not Royal FloraHolland regulations. You yourself are, and remain, at all times responsible for proper compliance with legislation and regulations in this regard.[1]

Would you like to know more?

With the above step-by-step plan and the accompanying information, we hope to have explained this complicated matter as simply and comprehensively as possible. Do you have any additional questions? Please don't hesitate to contact our Customer Contact Center, they will be happy to help you further.

[1] This newsitem is for information purposes only and does not constitute professional legal advice from Royal FloraHolland. Royal FloraHolland accepts no liability whatsoever with regard to the information in this newsletter and certainly not for compliance with the regulations of the German Packaging Act. Please seek independent legal advice for information that may specifically address your circumstances.

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