Germany’s Packaging Act is forcing OEMs to prioritise recyclability

Germany’s Packaging Act, introduced in 2019, requires manufacturers to avoid waste, promote reuse, and ensure packaging is recyclable. Unlike previous regulations, it is enforced by a central control authority under the Federal Environment Agency’s supervision, with fines reaching €200,000 for non-compliance. Since its implementation, automotive firms have had to overhaul their packaging strategies to meet tighter legal obligations.

In concrete terms, this means that packaging waste should be avoided as far as possible, or at least reduced, in the interests of environmental protection. 

How Germany’s Packaging Act affects OEMs and suppliers

The law applies not only to consumer-facing packaging but also to transport packaging, which is crucial for the automotive supply chain. Carmakers and suppliers must register their packaging in the Lucid public database and implement self-monitoring mechanisms to track recycling. Each packaging type—whether cardboard, plastic, wood, or metal—must carry specific recycling codes indicating material composition.

While environmental regulations are not new to the industry, the Packaging Act introduces far-reaching obligations. Its impact was already evident when it was introduced: in 2016, German manufacturers exported over 560,000 tonnes of packaging waste to China and Southeast Asia; by 2019, this had fallen to just 2,600 tonnes.

Read more: How smarter packaging design is becoming a competitive advantage in autonomous automotive logistics

Tighter requirements since 2022

Since 2022, manufacturers have been required to offer reusable packaging for final distribution and register all packaging in the Lucid system. This applies to materials such as cardboard, paper, glass, plastic, metal, cotton, wood, rubber, copper and ceramic.

The Act covers both system-participating packaging (which reaches end consumers) and non-system-participating packaging, such as transport packaging. As a result, the automotive industry is significantly affected by the legislation.

Obligations for automotive manufacturers

The automotive industry ships more goods daily than any other sector, surpassing even retail giants like Amazon. Vehicles and components must be securely packaged for transport, whether domestically or internationally, and manufacturers are responsible for ensuring compliance with the Act.

OEMs must document packaging compliance through self-monitoring mechanisms, covering all materials, including cardboard boxes, wooden pallets, plastic containers, protective films, and packaging chips. If a carmaker ships goods in its own packaging, it is classified as a distributor and must meet the legal requirements.

Even when purchasing packaging from third parties, OEMs must verify compliance with labelling regulations. Packaging must carry recycling codes, such as PAP 20 for corrugated cardboard, FOR 50 for wood, FE 40 for iron, and PP 05 for polypropylene. These codes are particularly important for multi-material packaging, where each material must be disposed of separately.

Labelling of reusable packaging

However, the automotive industry uses not only recyclable disposable packaging made of wood and cardboard, but also reusable packaging made of plastic or steel. These may not all be labelled, as they have been in circulation for at least seven years and many legacy containers predate the Act’s requirements. As a result, packaging without recycling codes is still in circulation, and it is not easy to see whether it has been disposed of properly at the end. 

Compliance is not only about protecting components but also ensuring that materials match procurement specifications. It is important that the materials used in the end are exactly those that were requested by the purchasing department. For instance, plastic containers must be produced using the specified plastic type without deviations.

Automotive packaging compliance: Logistics and sustainability

While the Packaging Act applies primarily within Germany, automotive firms must also account for its impact on imports and domestic distribution. Export packaging remains exempt, but any packaging used within Germany must comply. Additionally, automakers are responsible for the legal compliance of imported packaging when goods cross the border.

Given the automotive industry’s high shipping volumes, most packaging falls under the Act’s scope and must be either reusable or recyclable to reduce waste. Compliance is not only a responsibility for packaging manufacturers but also for OEMs, which must integrate sustainability into their supply chain strategies.

The shift towards greater accountability is forcing manufacturers and suppliers to prioritise sustainability alongside packaging performance. As one of the largest shippers of goods, the automotive industry faces a fundamental transformation in packaging procurement, disposal, and compliance tracking. These changes underscore the growing role of logistics in meeting environmental regulations and reducing industrial waste. 

This article first appeared on Automotive Logistics’ sister site, Neue Verpackung.