At a glance

The key facts of German packaging law, checked on 15 October 2026.

ItemStatus
Legal basisVerpackDG of 13 July 2026 (BGBl. 2026 I Nr. 207) and Regulation (EU) 2025/40[1][24]
In force since12 August 2026; the VerpackG applied until 11 August 2026[1][12]
Competent bodyCentral Agency Packaging Register (Zentrale Stelle Verpackungsregister, ZSVR) with the LUCID register (§ 6 Abs. 6)[4]
Obligated partiesProducers within the meaning of the PPWR that make packaging available in Germany for the first time[2]
Basic obligationsRegistration (§ 6), system participation (§ 7), data report (§ 9), above certain quantities a declaration of completeness (Vollständigkeitserklärung) (§ 10)[4][5][6][7]
Official costsLUCID registration free of charge; approval for packaging not subject to system participation is subject to a fee, amount still open[14][2]
Consequences of missing registrationPackaging may not be made available (§ 13); infringements are administrative offences (§ 66)[8][11]
Next deadlines12 November 2026: update registration data; 31 December 2026: old scheme contracts end at the latest[12]

Does the German Packaging Act still apply?

No. The German Packaging Act applied until 11 August 2026; since 12 August 2026, the VerpackDG has applied[1][12]. The reason is the PPWR: as an EU regulation, it applies directly and itself governs roles, requirements for packaging and the main elements of producer responsibility[24]. The VerpackDG supplements it only where the PPWR leaves room for national law, for example on compliance schemes, the register, deposits and administrative offences[1].

The Federal Environment Ministry (BMUKN) describes the aim as follows: the rules of the Packaging Act are retained as far as possible so that functioning schemes continue to operate[19]. The Bundestag passed the act on 11 June 2026[19]. In everyday use, the law is still often called the “Verpackungsgesetz” (Packaging Act). Today this means the VerpackDG, and who is obligated is determined by the PPWR roles[2]. Our guide to the PPWR (EU Packaging Regulation) explains these roles.

German Packaging Act and VerpackDG compared

The section numbers have changed. The table maps the familiar provisions to the new ones.

TopicGerman Packaging Act (until 11 August 2026)VerpackDG and PPWR (since 12 August 2026)
Who is obligatedProducer under § 3 VerpackG[20]Producer under Art. 3 Abs. 1 Nr. 15 PPWR; for conformity, additionally the manufacturer[2][24]
Registration§ 9 VerpackG[12]§ 6 VerpackDG; existing registrations remain valid (§ 68 Abs. 2)[4][12]
System participation§ 7 VerpackG[12]§ 7 VerpackDG; old contracts remain valid until 31 December 2026 at the latest (§ 68 Abs. 1)[5][12]
Data report§ 10 VerpackG[12]§ 9 VerpackDG; new: annual report by 1 June for less than 10 tonnes[6]
Declaration of completeness§ 11 VerpackG[12]§ 10 VerpackDG[7]
Take-back of packaging not subject to system participation§ 15 VerpackG[20]§ 39 VerpackDG; new: additional approval under § 19[9][23]
Ecological participation fees§ 21 VerpackG[19]§ 26 and new § 26a VerpackDG[19]
Deposit on single-use beverage packaging§ 31 VerpackG[18]§ 46 VerpackDG[10]
Appointment of an authorised representative§ 35 VerpackG, voluntary[2][20]§ 5 VerpackDG, mandatory for direct sales without an establishment[3]
Administrative offences§ 36 VerpackG[20]§ 66 VerpackDG[11]

Who is affected – and who is not?

The producer within the meaning of the PPWR is obligated. This is the first company in the domestic supply chain that makes packaging available in Germany. If a company has goods manufactured under its own brand, it is both manufacturer and producer (brand priority). If a company delivers directly from abroad to end users, it is itself the producer[2]. End users are consumers and commercial end customers who do not resell the goods[17].

There is no minimum quantity: registration and system participation apply from the first item of packaging[4][5]. The VerpackDG adopts the PPWR terms. It uses its own terms such as “Erstinverkehrbringer” (first placer on the market) only for individual obligations, for example for the deposit[21].

SituationProducer in Germany?What to do
Online retailer based in Germany sells products under its own brandyesLUCID, compliance scheme, data report; as manufacturer also a declaration of conformity[2]
Online retailer itself assembles boxes, tape and filling material into shipping parcelsyes, for the shipping packagingRegister the shipping packaging and arrange system participation for it[17]
Retailer buys packaged goods from a producer in Germany and sells them unchangedno, for these goodsCheck whether the producer is registered and participates in a scheme (§ 13 Abs. 3)[8]
Company imports packaged goods from a third country and sells them in Germanyyes, as the first company in the domestic supply chainRegistration, system participation, importer obligations under the PPWR[2][24]
Company without an establishment in Germany delivers directly to end users thereyesAs above, plus an authorised representative (§ 5 Abs. 2)[3][13]
Foreign supplier sells to a retailer in Germanyno, as a rule the German retailer isThe retailer takes on the producer obligations[2]
Bakery or snack bar uses service packaging that is only filled when handed overyesSystem participation can be requested from the upstream distributor; registration remains its own obligation (§ 7 Abs. 2)[5]
Producer supplies only industry or large commercial customersyes, without system participationRegistration, take-back under § 39 and, in future, approval; shipping packaging remains subject to system participation[4][9][17]
Small business with few parcelsyes, there is no minimum quantityFull obligations, but a simplified annual report for less than 10 tonnes[6]

Marketplaces and fulfilment service providers do not take on the producer obligations. However, they may not act for producers that are not properly registered. The ZSVR provides automated data matching for this purpose (§ 13 Abs. 4)[8]. Our article Which EPR proof do I need for Amazon.de? shows which proof Amazon requires.

Which packaging requires system participation?

Sales packaging, outer packaging, primary production packaging and transport packaging that typically ends up as waste at private households or comparable places of origin are subject to system participation, as is service packaging (§ 3 Abs. 6)[21]. Comparable places of origin include restaurants and catering businesses, hotels, canteens, hospitals, offices of the liberal professions and smaller craft businesses (§ 3 Abs. 7)[21].

Under the PPWR, shipping packaging in online retail counts as transport packaging. According to the ZSVR, it is subject to system participation without exception, including when shipped to commercial end customers[17]. This includes boxes, mailing bags, labels, tape and filling material[17].

Under § 11, the following do not require system participation[22]:

  • reusable packaging in an existing reuse system,
  • single-use beverage packaging subject to a deposit under § 46,
  • sales packaging of hazardous contents,
  • packaging that demonstrably does not reach end users in Germany.

For packaging not subject to system participation, take-back, recovery and annual documentation by 15 May apply (§ 39)[9]. Approval from the ZSVR is new (§ 19). As a transitional measure, producers may make packaging available without approval until 31 December 2027 (§ 68 Abs. 9)[23][12].

Obligations at a glance

The table shows the obligations of a producer of packaging subject to system participation. Further obligations that follow from the PPWR, such as the declaration of conformity and substance limits, are covered in the PPWR guide.

ObligationProvisionWhenWhere and how
Registration§ 6 VerpackDGbefore first making packaging available[4]LUCID, by the producer itself; master data, packaging types, brand names, declarations[14]
Reporting changes§ 6 Abs. 1 Satz 2without delay; for existing registrations by 12 November 2026[4][12]LUCID[14]
System participation§ 7 VerpackDGbefore making packaging available[5]Contract with one or more compliance schemes; state material type, mass and registration number[5]
Data report§ 9 Abs. 1without delay after each report to the scheme[6]the same data in LUCID[15]
Simplified data report§ 9 Abs. 2by 1 June of the following year if under 10 tonnes in the previous year[6]one bundled annual report in LUCID[15]
Declaration of completeness§ 10annually by 15 May, from 80 t glass, 50 t paper/paperboard/cardboard or 30 t other materials in the previous year[7][16]audited by a registered auditor, filed in LUCID[16]
Authorised representative§ 5 Abs. 2before first making packaging available, only without an establishment in Germany[3]written contract in German, appointment in LUCID[13]

The obligations are linked. Without registration, a producer may not make any packaging available; without system participation, it may not make available any packaging subject to system participation (§ 13 Abs. 1)[8]. Registration cannot be transferred to third parties; the same applies to the data report under § 9 (§ 5 Abs. 1)[3]. An authorised representative, by contrast, submits the data report in its own name[13].

Step by step: register, participate, report

This is how producers proceed when they make packaging available in Germany for the first time or check their registration.

  • **Clarify your role:** Are you the producer for product and shipping packaging, or does the obligation lie with your supplier? Brand, delivery route and registered office are decisive[2][17].
  • **If you are based abroad: appoint an authorised representative.** The authorised representative needs its own LUCID access, otherwise you cannot select it[13].
  • **Register in LUCID:** master data, packaging types, brand names and declarations. Registration is free of charge; the ZSVR issues a registration number[14][4].
  • **Engage a scheme:** a contract with a dual system covering material types and planned quantities. The ZSVR publishes a list of the schemes[17].
  • **Report quantities in LUCID:** planned quantities and every report to the scheme; under 10 tonnes, once a year by 1 June[15].
  • **Year-end closing:** reconcile actual quantities with the scheme; above the thresholds, file the declaration of completeness by 15 May[15][16].

Producers that are already registered check their entries against the new roles and correct them by 12 November 2026[12]. Our guide to the LUCID packaging register shows the LUCID process in detail. The guide to the packaging licence explains what participation in a scheme costs.

Authorised representative for companies not based in Germany

Since 12 August 2026, companies without an establishment in Germany that deliver directly to end users there must appoint an authorised representative. Previously this was voluntary[2]. An exemption is not possible[13].

  • **What the representative takes on:** system participation, quantity reports, the declaration of completeness, take-back obligations under § 39 and, where applicable, deposit participation[13].
  • **What remains with the producer:** registration in LUCID and maintenance of the registration data[13].
  • **Form:** only one authorised representative per producer, written authorisation in German (§ 5 Abs. 4)[3]. The contract is signed by hand or with a qualified electronic signature[13].
  • **Who is eligible:** an external person or company with its registered office or an establishment in Germany and its own authorised-representative login in LUCID. The ZSVR does not publish a list[13].

The appointment only takes effect once the authorised representative confirms it in LUCID[13]. Since 12 August 2026, producers from abroad that are already registered have been alerted to a missing authorised representative when they log in[2]. The act does not expressly state whether the 12 November 2026 deadline for changes to registrations also covers a late appointment[12]. This is an open question; the obligation itself has applied since 12 August 2026.

**Proposal at EU level:** The Commission has proposed suspending the PPWR obligation to appoint an authorised representative for EU companies until 2035. The proposal has not been adopted; the obligation applies[25]. Whether a suspension would also immediately remove the German rule in § 5 Abs. 2 VerpackDG is open. The provision is linked to Art. 45 Abs. 3 PPWR[3]. Our article EPR authorised representative: what the costs per EU country depend on explains what an authorised representative costs.

Deposit on single-use beverage packaging (§ 46)

The deposit obligation was previously set out in § 31 VerpackG and is now in § 46 VerpackDG[18][10]. First placers on the market (Erstinverkehrbringer) of single-use beverage packaging charge a deposit of at least EUR 0.25 including VAT per item of packaging. They label the packaging as subject to a deposit and participate in a uniform nationwide deposit system[10].

  • **Take-back:** Anyone who sells beverages subject to a deposit takes back empty packaging of the same material type and refunds the deposit. Below 200 m² of sales area, this is limited to their own brands[10].
  • **Online retail:** In distance selling, the final distributor must ensure return options within a reasonable distance of the end user (§ 46 Abs. 2)[10].
  • **Exceptions:** among others, beverages under 0.1 or over 3 litres, as well as wine, sparkling wine, spirits, milk and fruit juices. These exceptions do not apply to plastic bottles and cans (§ 46 Abs. 4)[10].

Single-use packaging subject to a deposit is exempt from system participation (§ 11)[22]. In future, however, its producers will need approval under § 19[23]. Our guide to the deposit in Austria shows how the deposit works in Austria.

Deadlines and transitional rules

The transitional rules are set out in § 68 VerpackDG. Several deadlines are still running.

DateWhat appliesStatus
13 July 2026VerpackDG signed into law, BGBl. 2026 I Nr. 207[1]done
12 August 2026VerpackDG and PPWR apply; obligation to appoint an authorised representative[1][2]in force
12 September 2026Registration for producers that only became subject to registration under the new law (§ 68 Abs. 2)[12]expired
12 November 2026Changes to existing registrations (§ 68 Abs. 2)[12]open
31 December 2026System participations under the old law end at the latest, unless otherwise agreed by contract (§ 68 Abs. 1)[12]open
12 February 2027Infringements of the PPWR can be prosecuted as administrative offences (§ 66 Abs. 2, § 68 Abs. 17)[11][12]adopted
15 May 2027Declaration of completeness for 2026: formally under the VerpackDG, in substance under the VerpackG[16]adopted
1 June 2027Simplified annual report for 2026 for less than 10 tonnes[6][15]adopted
31 October 2027Industry solutions and other producer responsibility organisations: latest date without approval (§ 68 Abs. 6, 7, 12)[12]adopted
31 December 2027Producers of packaging not subject to system participation: latest date without approval (§ 68 Abs. 9)[12]adopted

What does it cost?

The official costs are low; the main costs arise from system participation.

  • **Registration in LUCID:** free of charge[14].
  • **System participation:** The schemes set the fees, usually by material type and kilogram. In future, ordinances under § 26a are to regulate the ecological grading in more detail; how has not yet been determined[19].
  • **Declaration of completeness:** the registered auditor's fee, only above the thresholds[16].
  • **Authorised representative:** There are costs; you agree the amount with the authorised representative[13].
  • **Approval under § 19:** subject to a fee; in addition, an insolvency-proof security and a financing agreement with the ZSVR are required[2][23]. The amount has not yet been published.

Consequences of missing registration

If registration or system participation is missing, the packaging may not be made available in Germany. This applies to the producer and to retailers that resell its goods (§ 13 Abs. 1 and 3)[8]. The infringements are administrative offences under § 66 VerpackDG; the authorities of the federal states are responsible (§ 66 Abs. 4)[11].

SituationConsequenceProvision
Producer not registered or not correctly registeredmaking available not permitted; administrative offence[8][11]§ 13 Abs. 1, § 66 Abs. 1 Nr. 1
No system participationpackaging subject to system participation may not be made available; administrative offence[8][11]§ 13 Abs. 1, § 66 Abs. 1 Nr. 3
Retailer sells goods of an unregistered producerthe retailer may not make them available either[8]§ 13 Abs. 3
Fulfilment for an unregistered producerstorage, packing and dispatch not permitted[8]§ 13 Abs. 4
Marketplace offer without valid LUCID proofthe platform may not offer the products[17]§ 13 Abs. 4, Art. 45 Abs. 4 PPWR
Data report or declaration of completeness missingadministrative offence; the declaration must still be filed after the deadline[11][16]§ 66 Abs. 1 Nr. 6 and 7
Infringement of obligations under the PPWRadministrative offence from 12 February 2027[11][12]§ 66 Abs. 2, § 68 Abs. 17

If you have sold without registration so far, complete registration and system participation before your next sale. The order is shown in the “Step by step” section above.

Common mistakes

  • **Confusing registration and licence.** Registration in LUCID does not replace a scheme contract, and the scheme contract does not replace registration. Complete both before your first sale[8].
  • **Having the service provider register.** Registration is a strictly personal obligation of the producer, even with an authorised representative[13].
  • **Inconsistent data.** Name, tax number and registration number must match in LUCID, in the scheme contract and at the marketplace[14][15].
  • **Forgetting shipping material.** Tape, filling material and labels are part of the shipping packaging and are included in system participation[17].
  • **Carrying old roles forward.** Check by 12 November 2026 whether your producer role is still correct under the PPWR[12].
  • **Reporting only to the scheme.** Every report to the scheme also belongs in LUCID, except for the simplified annual report[15].
  • **Letting an old contract run out.** Scheme contracts under the old law remain valid until 31 December 2026 at the latest, unless otherwise agreed[12].

For companies from the Netherlands, Austria and Switzerland

Anyone who delivers directly from another country to end users in Germany is the producer there. LUCID registration, system participation, the data report and the authorised representative then apply[2][17]. If you sell to a retailer in Germany, the retailer is usually the producer[2]. Registration in your country of establishment does not cover Germany: producers register in every member state in which they first make packaging available (Art. 44 Abs. 2 PPWR)[24].

  • **Netherlands:** Whoever first makes packaging available in the Netherlands reports to Verpact[26]. Quantities you deliver directly to end users in Germany belong in your German system participation and report[17].
  • **Austria:** According to the Austrian environment ministry, the participation obligation under § 13g AWG 2002 continues unchanged for the time being[27]. For Germany, you also have to meet the German obligations. More on this in our article Selling to Austria: is the German packaging licence enough?.
  • **Switzerland:** Under the PPWR, Swiss companies are producers from a third country. For direct deliveries, they need an authorised representative in Germany[17]. The EU proposal for a suspension would change nothing for them[25].

The ClearoSystems needs analysis shows companies from the Netherlands, Austria and Switzerland their obligations in Germany per product, role, sales channel and country; we then support registration, reports and the appointment of an authorised representative.

Status and changes

As of 16 October 2026. Checked: the VerpackDG in the version on gesetze-im-internet.de, in particular §§ 3, 5 to 13, 19, 39, 46, 66 and 68. Also checked: the ZSVR topic pages on registration, data reports, the declaration of completeness, authorised representatives and online retail, as well as the BMUKN page on the act. We cross-checked the old sections of the German Packaging Act against § 68 VerpackDG, an information sheet from an authority and a legislation database. We will update this page when the ZSVR publishes the approval procedure or when a decision on the EU proposal on authorised representatives has been taken. Changes: 15 October 2026, first version; 16 October 2026, technical clarifications after expert review (summary on system participation and authorised representative). Translated from the German version of 16 October 2026.

Frequently asked questions

Where can I find the legal text of the VerpackDG?
You can find the current text free of charge on gesetze-im-internet.de under the abbreviation VerpackDG, as a web page, PDF or XML. The official text is published in the Federal Law Gazette (Bundesgesetzblatt) 2026 I Nr. 207. The old German Packaging Act is no longer available there as applicable law. You can find EU Regulation 2025/40 on EUR-Lex.
Do I have to create a new LUCID registration after 12 August 2026?
No. If you were registered under the German Packaging Act, you are also considered registered under the VerpackDG. However, you must check whether your details on role, packaging types and brand names are still correct, and make any changes by 12 November 2026. Companies from abroad also add their authorised representative.
I only send a few parcels a month. Do I still have to register?
Yes, if you are the producer of the packaging. The VerpackDG has no de minimis threshold. Small quantities only make reporting easier: below 10 tonnes in the previous year, an annual report by 1 June is sufficient, and a declaration of completeness is only required above the quantity thresholds. Many schemes offer tariffs for small quantities.
I only sell to businesses. Do I need system participation?
That depends on where the packaging becomes waste. If it arises at industrial or large commercial sites, you do not need system participation, but you do need registration, take-back and, in future, approval. If your customers, such as restaurants, offices or craft businesses, belong to the group of comparable places of origin, system participation applies. Shipping packaging must always be included in system participation.
What is the difference between registration and a packaging licence?
Registration is your company's free entry in the ZSVR's LUCID packaging register, which you make yourself. “Packaging licence” is the everyday term for system participation, that is, the paid contract with a dual system for collection and recycling. The law requires both.
Does the VerpackDG also apply to electrical equipment and batteries?
Only to their packaging. The equipment itself is covered by the Elektro- und Elektronikgerätegesetz (ElektroG, the German Electrical and Electronic Equipment Act), and batteries by the Batterierecht-Durchführungsgesetz (BattDG, the German Battery Act); the competent body there is stiftung ear (the German WEEE register), not the ZSVR. Anyone who sells packaged electrical equipment therefore often has obligations in two registers.

Sources

  1. [1]Verpackungsrecht-Durchführungsgesetz (VerpackDG) vom 13. Juli 2026, BGBl. 2026 I Nr. 207, Gesamtausgabe (accessed 15 Oct 2026)
  2. [2]ZSVR: PPWR und VerpackDG – das gilt seit dem 12. August 2026 (accessed 15 Oct 2026)
  3. [3]§ 5 VerpackDG – Beauftragung Dritter und Bevollmächtigung (accessed 15 Oct 2026)
  4. [4]§ 6 VerpackDG – Registrierung; zuständige Behörde (accessed 15 Oct 2026)
  5. [5]§ 7 VerpackDG – Systembeteiligungspflicht (accessed 15 Oct 2026)
  6. [6]§ 9 VerpackDG – Datenmeldungen (accessed 15 Oct 2026)
  7. [7]§ 10 VerpackDG – Vollständigkeitserklärungen (accessed 15 Oct 2026)
  8. [8]§ 13 VerpackDG – Verbot bestimmter Tätigkeiten in Bezug auf Verpackungen (accessed 15 Oct 2026)
  9. [9]§ 39 VerpackDG – Pflichten der Hersteller und Vertreiber zur Rücknahme und Verwertung (accessed 15 Oct 2026)
  10. [10]§ 46 VerpackDG – Pfand- und Rücknahmepflichten für Einweggetränkeverpackungen (accessed 15 Oct 2026)
  11. [11]§ 66 VerpackDG – Bußgeldvorschriften (accessed 15 Oct 2026)
  12. [12]§ 68 VerpackDG – Übergangsvorschriften (accessed 15 Oct 2026)
  13. [13]ZSVR: Alles auf einen Blick – die Bevollmächtigung (accessed 15 Oct 2026)
  14. [14]ZSVR: So registrieren Sie sich im Verpackungsregister LUCID (accessed 15 Oct 2026)
  15. [15]ZSVR: Pflicht zur Datenmeldung (accessed 15 Oct 2026)
  16. [16]ZSVR: Pflicht zur Vollständigkeitserklärung (accessed 15 Oct 2026)
  17. [17]ZSVR: Versand- und Onlinehandel – was ändert sich durch die PPWR? (accessed 15 Oct 2026)
  18. [18]Regierungspräsidien in Hessen: Erweiterte Pfand- und Rücknahmepflichten für Einweggetränkeverpackungen, Stand 13.02.2024 (accessed 15 Oct 2026)
  19. [19]BMUKN: Gesetz zur Anpassung des Verpackungsrechts an die Verordnung (EU) 2025/40 (accessed 15 Oct 2026)
  20. [20]buzer.de: Verpackungsgesetz (VerpackG), Inhaltsübersicht der letzten Fassung, nichtamtlich (accessed 15 Oct 2026)
  21. [21]§ 3 VerpackDG – Ergänzende Begriffsbestimmungen (accessed 15 Oct 2026)
  22. [22]§ 11 VerpackDG – Ausnahmen von der Systembeteiligungspflicht (accessed 15 Oct 2026)
  23. [23]§ 19 VerpackDG – Zulassung von Herstellern (accessed 15 Oct 2026)
  24. [24]Verordnung (EU) 2025/40 über Verpackungen und Verpackungsabfälle (PPWR), Amtsblatt-Fassung (accessed 15 Oct 2026)
  25. [25]Europäisches Parlament, Legislative Observatory: Verfahren 2025/0395(COD), COM(2025) 982 (accessed 15 Oct 2026)
  26. [26]Verpact: Jouw verpakkingen – producent onder de PPWR und drempelwaarden (accessed 15 Oct 2026)
  27. [27]BMLUK: Merkblatt zur EU-Verpackungsverordnung, 10.06.2026 (accessed 15 Oct 2026)