A lot of small businesses are confused about the recent changes to Germany’s packaging laws and how easy (or not!) it is to sell to German customers. Good news is it’s super quick to get set up and licenced!
Fun fact: Germany has had strict laws about declaring what packaging you’re importing for years, it’s just only recently launched a convenient central register to keep track of it all (which is why you're hearing more about it). It was introduced to encourage shops to use more sustainable packaging and to ensure that once it's in Germany, there's a higher likelihood of it being properly recycled. The new register, the LUCID Packaging Register, is where you’ll get a registration number and declare any packaging you’re sending into Germany. The register can be found here: https://lucid.verpackungsregister.org/.
There are three main steps you need to take to comply with the German packaging law:
- Register on LUCID (free, 5-10 minutes)
- Purchase a licence to import packaging (cost varies, 10-15 minutes)
- Report your packaging to LUCID (5 minutes)
1. Register with LUCID
To get set up, here’s a quick video on how to make an account.
You should register with your shop details and give your name as a representative, creating a login which is memorable to you. I am not a registered company in the UK but because I sell under my shop name (which is on all my customs forms, shipping labels, etc), that’s what I’ve used for registration. In some places (such as the US) you may also be asked for ID numbers, VAT numbers, and so on. The register is run by the German government and not a third party, so I was personally not concerned about providing my personal information. That said, if you are unsure I would recommend contacting the register for more information.
You/your company are a “Producer” for the purposes of the register. As a small shop selling mostly pins and stationery, I tend to only use cardboard and paper, so I chose that as my packaging choice. Of course, you should choose the packaging you use the most when shipping your products.
Once you’re registered, you’ll get an email from the register with an attachment. In that attachment (scroll down a few pages for the English version) is your LUCID registration number, which begins with DE followed by 13 numbers. You can get this number at any time from your LUCID Register dashboard:
2. Purchase a licence
Next, you’ll need to pay a fee through a third-party (called a Dual System Partner) to be able to import packaging into Germany. There are literally dozens of providers, and the LUCID Register recommends some of them here.
I personally went with Activate by Reclay because they were cheapest for me, but do check their websites (most are provided in English as well as German) and get prices for the amount of packaging you might send into Germany. I’ve heard that Grüner Punk is a well known name in the recycling world and is great if you ship a lot of orders to Germany. Their cheapest licence costs €25 for the rest of 2022 but that covers you for 100kg of cardboard (which in my case would be like 90-100 orders!). They have a calculator which easily shows you the cost of a licence. It’s worth bearing in mind that this is for 2022, of which there are only 6 months left (at the time of posting this blog). Prices will be more expensive next year because you’ll need to pay for all 12 months of 2023. You can switch licence providers at any time.
The great thing about the licence system is that you can top it up: I went for a 3kg cardboard/paper licence for 9 Euro (approx. £8/$9) in June to cover the remaining 6 months of 2022. 3kg is about right for my store (each order is around 10-15g of packaging, so this covers me for around 200 orders) but if I suddenly get a bunch more orders to Germany, I can add on extra kilograms of packaging as needed. You can usually pay with a credit card or PayPal.
Update on 15 May 2023: as of today, it looks like Activate by Reclay have bumped up their prices considerably and are now roughly the same as all other dual rep system partners. This therefore means my usual 3kg a year is now around £20-£25 rather than the £10-15 it has been previously. I have always included such costs in my 'shop running expenditure' figure (in the same way I do my Shopify fees, or costs to attend events) but if the cost is too high for you, I recommend reflecting it in your postage prices (as these should include all costs and fees to get the item from you to your customer!). Some shops may find bumping postage up by roughly £1-2 would be sufficient but this is a decision for you to make.
3. Report your packaging to LUCID
After getting your licence from a Dual System Provider, you need to go back to the LUCID Register and register the amount of kilograms of packaging you bought with your licence. After logging in to LUCID, head over to “Producer Data Report - Intra-year volume report”. It will ask you who your Dual System Partner is and then how many kilograms you purchased from them. Simply submit that info and that’s all there is to it! If you need to add more kilograms of packaging, just head back to your licence provider and increase your packaging allowance. Then, notify the LUCID register of this extra allowance (in the same way as just described).
You need to enter your LUCID number into your Etsy information so that Etsy knows you're complying with the packaging laws. If you head to Finances -> Legal and Tax Information -> Government Registrations -> German Lucid Information Number, enter your registration number (beginning with DE). Finally, you then need to tell your German customers that you are signed up to LUCID. It is actually mandatory to do this, though there isn’t an easy or obvious way to do so on Etsy. I would either send them a quick message after they place an order (making it clear that you are just sending the message for their information and that the customer doesn’t need to do anything further) or add an FAQ. In either case, I recommend the following wording:
Germany - Verpackungsgesetz (LUCID Packaging Register)
[YOUR SHOP NAME (e.g. Lunamise)] is registered with LUCID, which is the Packaging Register of the Stiftung Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR).
Producers/distributors pay a license fee to the dual system for the collection, sorting and recycling of the packaging they introduced to the market. My Dual System partner is [YOUR DUAL PARTNER (e.g. Activate by Reclay)].
Please recycle my packaging where possible - thank you!
If you also have your own website, you'll need to put this wording somewhere your customer can see (such as FAQs, in your shipping policy, or on product pages).
And that’s it! I know it seems like a lot, but it really does only take 20-30 minutes or so to get set up and then you don’t have to think about it again for a whole year (plus your customers in Germany will really appreciate it).
Please let me know if you have any questions on the process and I’ll do my best to help.