Plastic carrier bags and German Packaging Law: Rules for ≥50 µm, knot bags and LUCID

Which wall thicknesses are permitted for plastic carrier bags in Germany?

To implement European rules aimed at reducing the consumption of lightweight plastic carrier bags (Directive (EU) 2015/720), German legislation introduced a ban on specific wall thicknesses effective 1 January 2022 (originally Section 5 (2) VerpackG, continued under Section 12 (1) VerpackDG alongside the EU Packaging Regulation) [17], [18], [23].

German law distinguishes strictly according to film thickness in micrometres (1 µm = 0.001 mm) and point-of-sale purpose [17], [18]:

Bag wall thickness	Legal status in Germany	Typical retail & hospitality products
Under 15 µm (very lightweight plastic carrier bags)	Permitted if required as primary packaging for loose food (to prevent food waste) or for hygiene reasons [17], [18]	Thin produce knot bags / vest bags on rolls for loose fruit, vegetables and bakery goods [17], [18]
15 to under 50 µm (lightweight plastic carrier bags)	Prohibited for final distributors supplying consumers in Germany (including 'bioplastic' bags in this gauge) [17], [18]	Conventional thin checkout bags (may no longer be distributed in Germany) [17]
50 µm and above (sturdy plastic carrier bags)	Permitted, as the higher wall thickness is designed for multiple reuse [17], [18]	Sturdy T-shirt carrier bags from 50 µm, punched-handle bags and loop-handle bags [17]

For the German market, Pakzeno therefore supplies carrier bags exclusively from 50 µm upwards and produce knot bags on rolls under 15 µm. For destination countries outside Germany, permitted gauges follow the applicable national regulations of the recipient country.

Carrier bags as service packaging in Germany: LUCID registration and system participation

Under German packaging law, carrier bags, T-shirt bags, produce knot bags and takeaway bags that are filled with goods only at the point of sale (e.g. at a supermarket checkout, market stall, bakery or takeaway counter) to hand goods over to private consumers are classified as service packaging (Serviceverpackungen) [20].

Two core obligations apply to service packaging in Germany under Sections 6 and 7 VerpackDG (formerly Sections 7 and 9 VerpackG) [19], [20], [21]:

1. Registration in the LUCID packaging register: Every commercial final distributor in Germany that fills service packaging with goods and hands it to consumers must register with the Central Agency Packaging Register (ZSVR) in the public electronic register LUCID [20], [21]. Registration is free of charge and must be completed before placing packaging on the market for the first time [21].
2. System participation (licensing): Service packaging must participate in one or more German dual systems according to material type and mass to finance nationwide household collection and recycling [19], [20].

Pre-participation (pre-licensing): How licensing via the supplier works

German packaging law provides a major administrative simplification exclusively for unfilled service packaging (Section 7 (2) VerpackDG / Section 7 (2) VerpackG) [19], [20]: A retailer, bakery or restaurant that fills the bags at the point of sale does not need to sign its own contract with a dual system; instead, it can require its supplier (upstream distributor) to assume system participation for the delivered service packaging [19], [20].

When this pre-participation (pre-licensing) option is used, the process works as follows [20], [21]:

• The supplier licenses the sold quantity of carrier bags or knot bags with a German dual system and pays the system fee [20].
• The supplier confirms to the buyer on the invoice, delivery note or in a written confirmation that system participation has been completed for the supplied service packaging [19], [20].
• Important for the buyer: Even businesses that purchase exclusively pre-participated service packaging must still register once in the LUCID register as a final distributor and tick the box confirming they source exclusively pre-participated service packaging [20], [21].

Upon request, Pakzeno supplies carrier bags and produce knot bags for the German market with system participation included – the licence fee is then already included in the price and documented on the invoice.

Single-Use Plastics Fund Act (EWKFondsG) and SUP Directive

Alongside the Packaging Act, Germany enacted the Single-Use Plastics Fund Act (EWKFondsG) to transpose the European Single-Use Plastics Directive (Directive (EU) 2019/904, SUP Directive) [17], [22], [24]. Through the Single-Use Plastics Fund administered by the German Environment Agency (UBA) on the DIVID platform, producers of specified single-use plastic items finance municipal cleaning of public spaces [17], [22].

Under Annex 1 No. 5 EWKFondsG, the levy-liable product categories explicitly cover "lightweight plastic carrier bags: plastic carrier bags with a wall thickness below 50 micrometres, with or without handle, offered to consumers at the point of sale of goods or products, excluding very lightweight plastic carrier bags required for hygiene reasons or provided as primary packaging for loose food where this helps prevent food waste" [22]. Sturdy reusable and plastic carrier bags with a wall thickness of 50 micrometres or more therefore do not fall under the category of lightweight plastic carrier bags below 50 µm defined in Annex 1 No. 5 EWKFondsG [17], [22], [23].

View carrier bags & HoReCa bags from Pakzeno