Packaging Act requirements for artists and sellers shipping to Germany (VerpackG)
Learn more about packaging requirements for shops selling to German buyers.
Steps to sell to German customers
To sell an artwork to a German customer, you will be required to provide a LUCID ID before you complete the sale. If you don't already have a LUCID ID configured on your account, you must first sign up for the LUCID portal:
- Register yourself on LUCID: LUCID PORTAL
- Enter your LUCID details on section: MY ACCOUNT > SETTINGS > SALE SETTINGS
- Add LUCID ID number
Why are these steps required to sell on the German Market?
On January 1, 2019, Germany's VerpackG (Packaging Act) went into effect. This law has rules for online retailers, including Artmajeur artists who sell to buyers in Germany. The Packaging Act makes it easier to recycle and reuse materials used for packaging (e.g. cardboard boxes, tape, and bubble wrap). Recent changes to the Packaging Act include new rules that affect online marketplaces like Artmajeur and some sellers on Artmajeur. On July 1, 2022, the new rules will go into effect. Because these changes could affect your shop, we've listed the new requirements and important steps to take if you want to keep selling to buyers in Germany.
Friendly disclaimer: This information is meant to give you a general idea and is not legal advice. It is not meant to make a lawyer-client relationship, and getting it does not make one. Artmajeur doesn't take any responsibility for any losses, damages, or lawsuits that could happen because of or be related to how these materials are used. Please talk to a licensed lawyer in your area if you need legal help.
Who and what on Artmajeur falls under the Packaging Act?
The Packaging Act affects both domestic and international Artmajeur sellers who sell to German buyers.
It applies to all kinds of packaging that usually ends up in the trash after being used, like hang tags, cellophane bags, and boxes. It also applies to materials used to ship goods (e.g. mailing envelopes, boxes). Materials like cardboard, glass, aluminum, plastic, natural materials, cardboard composite materials, and more can be used as packaging.
Under the Packaging Act, these materials are considered to be the first "placement" of new packaging on the German market and must be recorded in the LUCID Packaging Register, which is run by the Central Agency Packaging Register (ZSVR).
This obligation only applies to sellers in Germany who didn't buy the packaging from a Dual System partner. There may also be special rules for packaging that can be used more than once if it is returned and reused as part of an incentive or deposit system. Even though each new rule can make things more complicated, most Artmajeur sellers who want to sell to buyers in Germany only have to follow three main steps, which are:
- Register yourself on LUCID: https://lucid.verpackungsregister.org/
- Choose a provider for the DUAL SYTEM: https://www.verpackungsregister.org/fileadmin/user_upload/How-to-Guide_en_13072018_final.pdf
- Tell your customers what they need to know about how to return items and recycle them (you can send them a message after you have made a sale)
What do I need to do if I want to sell to clients in Germany?
Register with LUCID. In order to sell online, sellers must sign up with the LUCID Packaging Register. You have to sign up before you can send anything to the German market. Even if you only get one order from a buyer in Germany, you have to sign up for LUCID and tell them about it. It's important to sign up as soon as possible.
Tell your customers how they can return items and recycle them. The Packaging Act also says that sellers have to tell buyers about their options for return and recycling. You can tell buyers about these things in your account's policies, by using the feature "Contact Client," or in a "Terms and Conditions" document. Visit LUCID or talk to a lawyer in your area to find out more about this requirement.
You'll need to add your LUCID number to your Artmajeur account. After you sign up for LUCID, you'll get a unique number that you'll need to give Artmajeur in your account settings. To add this to your account, do the following:
- Go to : My Account > Settings > Sale Settings
- Add LUCID ID number
If I don't sign up for LUCID, what will happen?
Online stores that don't follow the rules could get warning letters or be fined up to €200,000 and told they can't sell anymore. Registration is free, and everyone who is considered a "manufacturer" of packaging must register individually. This includes both domestic and international sellers on Artmajeur. For more information and to sign up, go to LUCID.
Despite the fact that LUCID registration is one of the key Packaging Act requirements, you should also be aware of the following:
Participating in a Dual System
A Dual System partner is a company to which you pay the licensing fee for your materials. In exchange, they collect and re-use the packaging after it has been used.
If you use a Dual System partner, you have to register your packaging and give an annual report on the mass (total weight) of the packaging you sell and the type of material it is made of. To meet all the packaging requirements, it's important to choose a system that is legal. The same amounts that are reported to the system must also be reported to the Central Agency at least once a year through LUCID.
Declaration of Completeness
Depending on how much packaging you put out into the world, you may also have to send in a declaration of completeness every year. If you put into circulation more than 80 tons of mandatory-participation packaging composed of glass, more than 50 tons of paper, board, or cardboard, or more than 30 tons of another material, you must comply with this requirement.
How can I make sure I'm following the Packaging Act?
Getting used to new compliance procedures can be hard. Visit the website of the Central Packaging Register Office for more information and resources. For questions about the Packaging Act, you can send a letter to [email protected]. If you have questions about how these rules might apply to your shop and how to follow them, you might want to talk to a lawyer. Even though Artmajeur can't make suggestions, there may be vendors in Germany and other European countries that help small businesses through this process.
What Artmajeur has to do according to the Packaging Act ?
Because of changes to the Packaging Act that go into effect on July 1, 2022, online marketplaces like Artmajeur are required to check that sellers have a valid LUCID registration and, if necessary, are taking part in a Dual System before any sales are made to the German market.
Consequently, there may be significant modifications to your capacity to sell to German buyers. In order for you to be able to sell on the German market, please register to the LUCID system as soon as possible.