Germany: The Declaration of Compliance, and Why LUCID Registration Is the Importer's Job

Two separate German obligations for imported woven packaging: an EU declaration of compliance for food contact, and LUCID registration under VerpackG.

German buyers of imported woven packaging are subject to two obligations that have nothing to do with each other, and confusing them is the most common cause of a stalled first order. The first is food-contact compliance, which is European law and concerns what the packaging is made of. The second is packaging waste, which is German national law and concerns who is responsible for the packaging becoming waste. Different legal instruments, different documents, different deadlines, and only one of the two is something an Indian manufacturer can materially help with. Knowing which is which saves a month.

Food contact: the declaration of compliance and what belongs in it

The framework instrument is Regulation (EC) No 1935/2004, and for plastics the specific measure is Commission Regulation (EU) No 10/2011, which sets migration limits for substances used in plastic food-contact materials and conditions for their use. The mechanism that carries compliance down the supply chain is documentary. Article 16(1) of Regulation 1935/2004 requires that materials and articles covered by a specific measure be accompanied by a written declaration of compliance, and Regulation 10/2011 requires that at marketing stages other than retail, a written declaration in accordance with that article be available for plastic materials and articles, containing the information laid down in its Annex IV. Compliance is documented by the responsible business operator and made available to their customers.

For a woven polypropylene bag, the declaration has to describe the article that actually exists, which means the construction and specifically the layer in contact with the food. On a laminated or lined bag that is the coating or liner, not the outer weave, and the supporting migration evidence has to have been generated against that construction. A declaration issued for a different lamination is not a declaration for yours. This is also why changing the liner on a repeat order is a documentation event: the article changed, so the paperwork describing it has to change with it.

Packaging waste: LUCID, and the rule that catches foreign sellers

The German Packaging Act, VerpackG, established the LUCID Packaging Register as the central registry recording manufacturers of packaged products and monitoring their packaging licensing obligations. The rule to note is its reach: every company distributing packaged goods commercially in Germany, or importing packaged goods into Germany, must register with LUCID regardless of where that company is based. Registration is free and completed online. Failure to comply can bring fines and a distribution ban on the products concerned, which is a commercially fatal outcome rather than an administrative annoyance.

Where this bites in a woven packaging deal is in distinguishing the packaging you are selling from the packaging your goods arrive in. If you are importing empty bags to fill and sell in Germany, the bags become the packaging of your own product and the obligation attaches to you as the party placing that packaged product on the market. The pallets, stretch film and outer cartons in which the empty bags themselves travelled are separate transport packaging with their own reporting. Both need to be accounted for, and the tonnage reporting is by weight and material, so it needs actual figures rather than estimates.

Layered above the national act, the EU Packaging and Packaging Waste Regulation, (EU) 2025/40, entered into force on 11 February 2025 and takes effect from 12 August 2026, and it applies to every business placing packaged goods on the EU market, importers and online marketplaces included. It requires that packaging be recyclable and, on its own phased timetable, that plastic packaging contain minimum recycled content, with producers bearing the costs of collection, recovery and recycling. Two cautions are worth stating plainly: the recycled-content obligations run to their own dates rather than all applying immediately, and recycled plastic destined for food contact is subject to a separate and considerably tighter authorisation regime than recyclate used in non-food packaging. Both points need checking against the current text for your own product and date.

What German buyers ask for that others do not

German procurement in this category tends to be documentary-first, and that changes what a good enquiry looks like. Expect questions about the additive package rather than only the polymer, about print ink systems and which surface carries them, about whether the contact layer uses virgin resin, and about how a claimed GSM is verified in production rather than merely specified. Expect also to be asked for a mono-material position, because a single-polymer construction is easier to place in a recycling stream than a mixed one, and recyclability is now a regulatory attribute rather than a marketing line.

Ask the supplier for

Construction, contact-layer composition, resin grades, additives, ink system and print position

Commission

Migration testing against the exact construction, under the applicable EU conditions

Register yourself

LUCID, if you distribute or import packaged goods in Germany, wherever you are based

Report accurately

Weight and material of both product packaging and transport packaging

Check dates

Which PPWR obligations apply to your product now, and which apply later

Treat as a change

A liner or lamination change means a new declaration, not just a new price

In practice the German enquiries that convert are the ones where the commodity is named up front. A printed rice bag reaching a retail shelf is a different documentation problem from a laminated sugar sack going into a processing plant, and both differ again from an animal feed sack, where the food-contact question and the moisture-barrier question happen to point the same way. Where the buyer converts locally, the article being documented is the laminated fabric roll rather than a finished bag, and the declaration has to describe that instead. Naming the commodity and the form of supply removes most of the back-and-forth.