Packaging licence in Germany 2026: who needs one, what it costs and how to proceed

At a glance

What "packaging licence" means

There is no licence in the legal sense. The law speaks of system participation: the producer participates in a scheme with its packaging and states the material type, the mass and its registration number^[2]. The scheme confirms the participation in writing or electronically^[2]. The ZSVR itself writes "Systembeteiligungsvertrag (Verpackungslizenz)", i.e. system participation contract (packaging licence)^[3].

A compliance scheme (dual system) is an approved producer responsibility organisation that collects and recovers packaging from households and comparable places across the whole country^[4]. In everyday life, these are the yellow bin, the paper bin and the bottle bank^[1].

The packaging licence is one of three obligations that belong together:

• Registration in the LUCID packaging register, free of charge and done by the producer itself. It is not a licence and does not replace one^[19]. How it works is shown in the guide to the LUCID packaging register.
• System participation with one or more schemes, subject to a fee^[2][19].
• Data report: report the same volumes in LUCID as well^[9].

If one of the three steps is missing, you may not make the packaging concerned available in Germany^[18].

Who needs a packaging licence

The producer must license. Under the PPWR, this is the company that first makes the packaging available in Germany; if a company abroad delivers directly to end users, it is itself the producer^[20]. Whoever designs the packaging or has it manufactured under its own brand is the manufacturer and is responsible for its conformity; that is a separate role^[20].

In addition, no system participation is needed for reusable packaging in a reuse system, single-use beverage packaging subject to a deposit, sales packaging of contents containing hazardous substances, and packaging that demonstrably does not go to end users in Germany (§ 11 VerpackDG)^[8]. For packaging that you deliver to comparable sources of waste such as hotels or canteens, § 8 VerpackDG allows an approved sector solution (Branchenlösung) with its own take-back instead of a scheme^[23].

Which packaging must be licensed

Subject to system participation are sales and grouped packaging, primary production packaging and transport packaging that typically ends up as waste mainly at private households or comparable sources of waste, as well as all service packaging^[4]. What counts is the overall market for packaging of the same type, not your individual customer^[5]. Comparable sources of waste include restaurants and catering, hotels, canteens, hospitals and schools^[4].

Whether a product packaging falls under this is shown in the ZSVR's catalogue of packaging subject to system participation. Service packaging and shipping packaging are not listed there because they are always subject to system participation^[5]. Under the PPWR, shipping boxes count as e-commerce packaging and must be licensed even when they go to industrial customers^[6].

Pre-licensed service packaging, for which the supplier has already paid, has only been possible in exceptional cases since 12 August 2026, for example when neutral goods from abroad are subsequently given your own brand (§ 7 para. 2 VerpackDG)^[2][7].

How to conclude system participation

• Clarify role and packaging: check for each product and packaging component whether you are the producer and whether it is subject to system participation^[5][20].
• Record weights: ask your suppliers for the material and weight of each packaging, for own brands and imports including the product packaging^[21].
• Register in LUCID: without a registration number, the scheme cannot assign your participation^[2].
• Choose a scheme and sign the contract: you state the expected annual volumes per material, the planned volumes^[10].
• Check the confirmation: the scheme confirms material type and mass; your registration number must appear in it^[2][10].
• Report volumes in LUCID: transfer the details from the contract to LUCID before the first delivery goes out^[9][10].

Without an establishment in Germany, your authorised representative for extended producer responsibility (EPR) takes over steps 4 to 6 in its own name; the registration remains with you^[26].

What a packaging licence costs

The cost of system participation depends mainly on the volume and material type of your packaging^[1]. Each scheme sets its own prices. The ZSVR may neither advise on the choice nor give information on prices^[15]. Offers can therefore only be compared reliably with your own volumes.

When setting their fees, schemes must create incentives for easily recyclable packaging and for recycled materials (§ 26 VerpackDG)^[13]. A statutory ordinance under § 26a VerpackDG is to define exactly what this ecological design must look like; its content had not yet been settled on 15 October 2026^[14].

This is how you calculate your fee. The volumes are fictitious assumptions for the calendar year 2027; prices are variables because they differ by scheme and contract:

Summarised in four steps: determine your role and the parts that must be licensed; multiply the weight per part by the number of units to get kilograms per material; obtain offers with a price per kilogram and material; later reconcile the planned volumes with the actual volumes. If goods are taken back damaged or unsaleable and recovered, you can reclaim fees already paid from the scheme, provided you document this (§ 7 para. 3 VerpackDG)^[2]. Registration in LUCID costs nothing^[19]. A calculation for several countries is shown in our article on packaging costs in Germany, the Netherlands and Austria.

Data report: the figures must match

You enter every volume report to your scheme without delay and 1:1 in LUCID as well, with registration number, material type and mass, name of the scheme and period^[9]. You enter volumes in kilograms with three decimal places^[10]. The schemes also report their customers' volumes to the ZSVR, and the ZSVR reconciles both sides^[10].

• Reporting frequency: it follows your contract, for example monthly, quarterly or annually^[10].
• Planned volume: the initial planned volume for the following year can only be entered in LUCID until 31 December^[10].
• Actual volumes: the year-end volume report for the previous year is possible until 1 June; after that, a supplementary report follows^[10].
• Discrepancies: correct them first with the scheme, then in LUCID^[10].
• Small volumes: below 10 tonnes in the previous year, one bundled annual report by 1 June is sufficient^[9].
• Large volumes: from 80 tonnes of glass, 50 tonnes of PPK or 30 tonnes of other materials combined, a declaration of completeness confirmed by a registered auditor is due by 15 May^[11][12].

Deadlines and timeline

Consequences of missing system participation

Without system participation, you may not make packaging subject to system participation available in Germany; the same ban applies to retailers who offer your goods^[18]. Online platforms obtain a self-certification before the sale that you meet your producer obligations in the consumer's country (Art. 45 para. 4 PPWR)^[22]. Missing system participation, a missing data report or a missing declaration of completeness is an administrative offence under § 66 para. 1 no. 3, 7 and 6 VerpackDG^[17]. The law expressly also covers incomplete participation, for example when only part of the packaging is participating^[17].

Small businesses and small traders

§ 7 VerpackDG has no exemption based on size, turnover or number of employees; the obligation applies from the first packaging^[2]. Small traders (Kleingewerbe) also register with their business tax number^[19]. Small businesses get relief in three places:

• Reporting: below 10 tonnes in the previous year, one annual report is sufficient^[9].
• Declaration of completeness: below the thresholds it is not required, unless the ZSVR or the competent state (Land) authority requests it^[11].
• Own brands of micro-enterprises: if a micro-enterprise with fewer than 10 employees and a turnover or balance sheet total of no more than EUR 2 million has packaging made under its own brand by a supplier in the same member state, the supplier is the manufacturer (Art. 3 para. 1 no. 13 point b PPWR); in its case examples, the ZSVR also assigns the producer obligations to the supplier^[7][20][22]. If the supplier is based in another EU state, the ZSVR treats the micro-enterprise itself as the manufacturer, while Art. 15 para. 12 and Art. 21 PPWR refer to a supplier "in the Union"; this case has not been conclusively settled^[20][22].

With only a few parcels, the fee is lower because of the small mass. Registration, contract and reporting nevertheless remain mandatory.

Choosing a scheme

You can choose the scheme freely and also split your volumes across several schemes^[1][2]. The ZSVR publishes the list of approved scheme operators with contact details; it does not give a recommendation^[15]. Check offers against these criteria:

• Price per kilogram for each material type you actually use, for your volumes.
• Minimum or flat fees, VAT and costs for late reports.
• Term, notice period and settlement of excess or shortfall volumes compared with the planned volume.
• Reporting frequency and whether the volume confirmation contains your LUCID registration number^[10].
• Handling of refunds for damaged or unsaleable goods under § 7 para. 3 VerpackDG^[2].
• Assess additional services separately: an authorised representative is a separate role with its own contract and its own costs^[25].

Also check whether your contract continues after 31 December 2026; older contracts end by law at that date at the latest, unless otherwise agreed^[16]. How to compare offers for the same volume and term is shown in our article comparing packaging licences.

Common mistakes

• Only the shipping box licensed. Solution: include adhesive tape, filling material, labels and the product packaging, insofar as you are the producer for them^[6].
• Licence concluded before registration. Solution: LUCID first, then the scheme contract with the same registration number^[2].
• Planned volumes reported, actual volumes forgotten. Solution: year-end report by 1 June with the scheme and in LUCID^[10].
• Different volumes in the scheme and in LUCID. Solution: transfer reports 1:1^[9].
• Own brands and imports not licensed retroactively. Solution: since 12 August 2026, the obligation lies with the retailer; add the volumes and enter the brands in LUCID^[21].
• Single-use plastics levy (Einwegkunststoffabgabe) offset against the licence. Solution: both payments apply side by side; offsetting is not permitted^[1].

For companies from the Netherlands, Austria and Switzerland

System participation in your home country does not cover Germany: § 7 VerpackDG requires participation in a scheme in the federal territory^[2]. Conversely, a German licence does not apply in Austria or the Netherlands. What is additionally required in Austria is shown in our article selling to Austria.

If you deliver directly to end users without an establishment in Germany, you need an authorised representative for extended producer responsibility. The representative concludes the scheme contract and reports the volumes in its own name; you carry out the registration in LUCID yourself^[25][26]. This applies to companies from EU states as well as from Switzerland^[6]. If, on the other hand, you supply a German retailer who resells, the retailer licenses the packaging^[20]. How registration and roles fit together under the new law is explained in the guides to the German Packaging Act and the VerpackDG and to the PPWR. In a digital needs analysis for companies whose home market is the Netherlands, Austria or Switzerland, ClearoSystems clarifies per product, role, sales channel and country which obligations apply, and then supports registration, reports and the appointment of an authorised representative.

Status and changes

As of 16 October 2026. On that day we checked §§ 3, 5, 7, 8, 9, 10, 11, 13, 26, 26a, 39, 42, 66 and 68 VerpackDG on gesetze-im-internet.de, Art. 3, 45 and 71 of Regulation (EU) 2025/40 and the ZSVR pages on system participation, data reporting, the declaration of completeness, the catalogue and the list of scheme operators^[2][15][22]. We did not find an adopted ordinance under § 26a VerpackDG. Changes: 15 October 2026, first version; 16 October 2026, technical clarifications after expert review (own brands of micro-enterprises in the overview). Translated from the German version of 16 October 2026.

Frequently asked questions

As a small trader with only a few orders a month, do I need a packaging licence?

Yes, as soon as you ship goods to customers in Germany in packaging for which you are the producer. There is no minimum volume. The contract is based on your planned kilograms per material; what matters is that all materials are covered and that the report in LUCID matches the report to the scheme.

Is it enough if my supplier has already licensed the packaging?

Only for the packaging for which your supplier is actually the producer, for example the product packaging of a third-party brand that a German wholesaler made available first. For boxes, padding and adhesive tape that you put together into shipping packaging yourself, you are the producer and license them yourself.

Is the packaging licence the same as the EPR number?

No. The EPR number for packaging in Germany is the LUCID registration number. The licence is the contract with a scheme. Before the sale, online platforms must obtain the number and a self-certification that you meet your obligations; you prove system participation with the confirmation from your scheme.

Can I switch schemes?

Yes, under the terms of your existing contract. With the new scheme, you state the same registration number and report the volumes in LUCID with the name of the new scheme and the correct period, so that the reports can be assigned without gaps.

I export part of my goods. Do I have to license this packaging in Germany?

No, if you can prove that this packaging is not handed over to end users in Germany. Document the export volumes separately. In the destination country, its own rules apply, under which you may be the producer there.

What happens if my volumes at the end of the year are higher than planned?

You first report the actual volumes to your scheme, which settles the difference according to the contract, and then enter the same volumes in LUCID. For the past year, this is possible as a year-end volume report until 1 June, and after that as a supplementary report.