Germany VerpackG and France Triman: EPR Registration for Food Packaging

Germany: LUCID registration

The Verpackungsgesetz (Packaging Act) requires anyone who places packaging on the German market to register with the ZSVR and obtain a LUCID registration number. This includes packaging that ends up as waste with the consumer — which is exactly what a food container is.

The sequence:

1. Register in LUCID and receive an LUCID number
2. Register with a dual system (Der Grüne Punkt, Interzero, Veolia and others) and pay the licence fee
3. Report volumes annually, in tonnes, by material
4. List the brand names you sell under — this is the step most exporters miss

The LUCID number must be visible on the packaging or the invoice in some cases, and market surveillance checks it. A container shipped to a German distributor without the distributor holding a registration is a compliance gap for the distributor, and they will push it back to you.

France: Triman and EPR

France requires the Triman logo plus a sorting instruction on packaging, with the "Info-tri" format now the standard. The producer joins an EPR scheme (Citeo for household packaging) and pays a fee modulated by recyclability.

For a PP container, this means:

• Triman logo printed on the container or the lid — usually in-mould, which means it is in the print plate
• Sorting instruction in French
• Registration with the scheme, by the producer, not the factory

The logo cannot be stickered on after the fact in most programmes — it must be printed. If you approve artwork without it, you approve a re-print.

Italy and Spain, briefly

All follow the same logic: register, report weight by material, pay, mark.

The data your customer needs from you

EPR fees are calculated by weight and material. To report, the producer needs:

This is where a factory declaration becomes commercially useful. Not a certificate — a simple signed sheet listing weight and material per SKU. Buyers who have done this before will ask for it in the first email. Buyers who have not will ask for it after their first EPR invoice, in a panic.

The cost, in perspective

For a 20 g PP container, the EPR fee in Germany or France is a fraction of a cent per piece. It is not a pricing problem. It is a timing problem: if the packaging is already produced without the required mark, the fix is a new print run.

Two rules:

• Ask the destination country before approving artwork. France needs Triman; Germany does not require a mark but requires registration.
• Keep the per-SKU weight sheet updated. Changing the wall thickness changes the declared weight, which changes the fee, which creates a reconciliation problem at year end.

FAQ

Does the factory have to register? No. The obligation is on the producer placing the packaging on the market — normally your customer, unless you sell direct to end users in that country.

Can I use one registration for all of Europe? No. EPR is national. Germany, France, Italy, Spain and the Netherlands each have their own scheme and their own fee.

Is a paper label a problem? It is a second material stream and must be declared separately. It also complicates recycling. In-mould labelling avoids both issues.

What happens if the Triman logo is missing? The packaging is non-compliant in France. The producer carries the liability, and the practical remedy is a reprint.

Related reading

• EU Single-Use Plastics Directive: Where PP Containers Stand
• Private Label Program for Distributors
• How to Buy Disposable Food Containers Wholesale from China: MOQ, Pricing and Lead Time

Models covered on this site: 2500 ml PF-RW2500 · 1000 ml PF-RW1000 · 750 ml PF-GG750 · see all models in this category.