The new Packaging Act: what online retailers need to watch out for from July 2022

Fatih-Kağan Taşkoparan

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The growing mail order business is seen as a driver of packaging waste - and no wonder: online retail is booming and the flood of parcels is constantly increasing as a result. The packaging amendment is intended to do an even better job of ridding the environment of plastic waste and has a direct impact on online retail: retailers and fulfillment service providers will be subject to stricter controls and obligations in future. We have summarized the important changes that will play a major role here, especially for online retailers.

What is the Packaging Act?

The Packaging Act has been in place since 1.1.2019. The aim is to involve those who put packaging into circulation in the disposal and recycling of packaging. Originally, only those who produce "system-involved packaging" were made liable for this: Put simply, this is sales packaging and secondary packaging that typically becomes waste with private end consumers. However, this also includes transport packaging.

Does this affect me at all as an online retailer?

From 1.7.2022, changes to the law will come into force. As an online retailer, you will then also have to take specific action if you

  1. operate a marketplace or
  2. Fulfilment service provider:in bist

What do I have to do?

As a marketplace operator or fulfillment service provider, your duties include the following from July 1, 2022:

What this means for you as a marketplace operator is that you should start making inquiries to your retailers now and obtain the registration number for the LUCID register.

As an online retailer, you will be held more accountable in the future, but as a fulfillment service provider, you will no longer have to purchase licenses yourself when you fill shipping packaging. Instead, the retailer who commissions you will have to take care of this.

What happens if I don't stick to it?

If you cannot provide proof of this from your dealers, this can be tricky: This is because you are not allowed to offer the goods or enable their sale, nor are you allowed to store, pack, address or ship them. It is therefore de facto prohibited to sell products if the packaging has not been verifiably licensed.

What else is new?

In addition, there are other changes that may also indirectly affect you as an online retailer. These include

What do I have to do if I am subject to licensing?

If you have to license your packaging yourself, the following steps are on your agenda:

  1. You must first register in the LUCID packaging register.
  2. The next step is to license the packaging in a dual system (there are various providers).
  3. And finally, you must state in the LUCID what quantity of packaging you have licensed with which dual system.

Watch out: If you do not comply with the Packaging Act, you may be subject to expensive fines.


For online merchants, the upcoming changes will entail particular effort if you operate a marketplace and offer fulfillment services. However, if you prepare for the changes now, the ongoing effort will be relatively low.

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