Data reporting under the VerpackDG: Obligations, information and deadlines

When do these rules apply?

Under the version currently available, the VerpackDG enters into force on 12 August 2026 (Article 8(7) of the Packaging Law Adaptation Act). The PPWR, Regulation (EU) 2025/40 on packaging and packaging waste, also applies from 12 August 2026 under Article 71 PPWR.

The obligations described below refer to the legal position from that date. Transitional provisions described further below additionally apply to packaging you make available during the 2026 calendar year.

Who is required to submit data reports?

Manufacturers that participate in one or more systems with packaging subject to the system participation obligation must submit data reports under Section 9 VerpackDG.

Who qualifies as a manufacturer is determined by Article 3(1)(15) PPWR. Under this provision, a manufacturer is any producer, importer or distributor falling within one of the scenarios described in points (a) to (e). The decisive factor is therefore not the company designation, but the specific situation.

One of these scenarios concerns unpacking, under point (e). It applies only if both of the following conditions are met:

• Your company unpacks packaged products without being an end user; and

• No other party already qualifies as a manufacturer under points (a), (b), (c) or (d).

Therefore, merely unpacking goods as a commercial recipient does not automatically create manufacturer obligations.

Further obligations in addition to data reporting

• Registration with the Central Agency Packaging Register (Zentrale Stelle Verpackungsregister, ZSVR) before making packaging available for the first time or before unpacking it (Section 6(1), sentence 1 VerpackDG)

• Participation of packaging subject to system participation in one or more systems before making it available or before unpacking it (Section 7(1), sentence 1 VerpackDG)

• Data reporting to the Central Agency Packaging Register (Section 9 VerpackDG)

• Where applicable, a declaration of completeness (Section 10 VerpackDG)

Under Section 5(1), sentence 1 VerpackDG, you may generally engage third parties to fulfil your obligations. However, under sentence 2, this does not apply to registration under Section 6 or submission of data reports under Section 9. You must complete these two steps yourself. A service provider may support you organisationally, but the legal responsibility remains with you.

Which packaging must you include?

Data reporting under Section 9 VerpackDG relates to packaging subject to system participation. Section 3(6) VerpackDG covers:

• Sales and grouped packaging;

• Primary production packaging; and

• Transport packaging;

where, after use and based on the overall market for packaging of the same type, this packaging typically becomes waste predominantly in private households or at comparable places of waste generation.

Service packaging is listed separately in Section 3(6) VerpackDG. According to the wording of the provision, the majority criterion described above does not additionally apply to service packaging.

The name of the packaging or the distribution channel alone is not sufficient for classification. For transport packaging in particular, the decisive issue is where packaging of the same type actually becomes waste after use.

We advise you on all matters relating to the VerpackDG/PPWR:

PPWR consulting

Which exemptions apply under Section 11 VerpackDG?

Sections 7 to 10 VerpackDG – meaning system participation, data reporting and the declaration of completeness – do not apply under Section 11 VerpackDG to manufacturers of:

1. reusable packaging, where actual take-back and reuse are enabled through an established reuse system;

2. single-use beverage packaging subject to a deposit obligation under Section 46 VerpackDG;

3. sales packaging containing hazardous substances;

4. packaging that can be demonstrated not to be supplied to end users in Germany.

Review these exemptions before assuming that a reporting obligation applies.

What applies to service packaging?

Under Section 7(2), sentence 1 VerpackDG, a manufacturer of service packaging subject to system participation may require its upstream distributors to participate in one or more systems in respect of the unfilled service packaging they supply.

Under Section 7(2), sentence 3 VerpackDG, this transfer also shifts the manufacturer obligations under Sections 6, 9 and 10 VerpackDG to the obligated upstream distributor to that extent. However, the original manufacturer remains subject to the registration obligation.

What applies to industry solutions?

Under Section 8(1) VerpackDG, the system participation obligation under Section 7(1) VerpackDG does not apply where a manufacturer takes back packaging subject to system participation from comparable places of waste generation free of charge through an industry solution and sends it for recovery.

This directly affects data reporting: Where there is no obligation to participate in a system, the scope of packaging that must be reported under Section 9(1) VerpackDG is correspondingly limited.

Which information must be reported?

Under Section 9(1), sentence 1 VerpackDG, you must submit at least the following information to the Central Agency Packaging Register:

1. Your registration number;

2. The material type and mass of the packaging included in the system;

3. The name of the system through which system participation was carried out;

4. The period for which system participation was carried out.

Material types and masses must be broken down according to the material types listed in Section 42(2), sentence 1 VerpackDG. Other materials must each be consolidated into a single standard entry (Section 9(1), sentence 3 VerpackDG).

Where this information changes, or packaging is taken back under Section 7(3), sentence 1 VerpackDG, the updated information must also be reported accordingly (Section 9(1), sentence 2 VerpackDG).

Reconciliation with system participation

You must report the information submitted as part of system participation. The confirmation issued by your system serves as the basis: Under Section 7(1), sentence 3 VerpackDG, the system must promptly confirm completed participation in writing or electronically, stating the material type and mass of the included packaging. This also applies where participation was arranged through an engaged third party.

When must data reporting take place?

Under Section 9(1), sentence 1 VerpackDG, you must submit the information to the Central Agency Packaging Register without delay after submitting it to the system. Section 9(1) VerpackDG does not specify a different annual deadline for this report.

The timing of your quantity report to the system may be determined by your system participation contract. Once you have submitted information there, the obligation to report it without delay to the Central Agency Packaging Register applies.

Separate deadlines apply in two other cases: the annual report for small quantities by 1 June (Section 9(2) VerpackDG) and the declaration of completeness by 15 May (Section 10(1), sentence 1 VerpackDG).

What applies below ten tonnes?

Under the VerpackDG

If, in the previous calendar year, you made available in Germany a total of less than ten tonnes of packaging subject to system participation, or unpacked such packaging in the scenario described in Article 3(1)(15)(e) PPWR, you are exempt under Section 9(2), sentence 1 VerpackDG from the obligations in Section 9(1), sentences 1 and 2. The exemption therefore also covers reports of changes and take-backs.

Instead, under Section 9(2), sentence 2 VerpackDG, you must submit all information under Section 9(1), sentence 1 by 1 June of the following calendar year. This annual report must also be broken down by material type, as Section 9(1), sentence 3 applies accordingly (Section 9(2), sentence 3 VerpackDG).

The rule is based on total mass. At exactly ten tonnes, it does not apply according to its wording, because Section 9(2), sentence 1 VerpackDG requires a quantity of less than ten tonnes.

This relief concerns only the timing of data reporting. Registration under Section 6 and system participation under Section 7 VerpackDG remain unaffected.

Under the PPWR

At European level, reporting does not disappear below ten tonnes. Under Article 44(8) PPWR, manufacturers must submit a simplified data set under Part B, point 2 of Annex IX PPWR by 1 June in this case.

Two opening clauses must be considered:

• Under Article 44(8), second subparagraph PPWR, a Member State may establish a lower threshold.

• Under Article 44(9) PPWR, a Member State may require quarterly reporting.

How do planned quantities and adjustments during the year work in LUCID?

In practice, data reporting is submitted through the LUCID Packaging Register. The basis for this is Section 9(3) VerpackDG: The Central Agency Packaging Register may provide standard electronic forms for data reporting and issue further procedural instructions.

The terms “planned quantity report”, “in-year quantity report” and “year-end quantity report” do not appear in the legal text itself. They describe practical reporting occasions in the procedure and do not replace the basic rule in Section 9 VerpackDG.

Planned quantity report

A planned quantity report reflects forecast packaging quantities for a future period. Section 9 VerpackDG does not establish a general statutory deadline for this. What remains decisive is that information submitted to the system must also be reported without delay to the Central Agency Packaging Register.

In-year quantity report

If quantities included in the system change during an ongoing forecast period, the updated information must also be reported under Section 9(1), sentence 2 VerpackDG. Differences between information held by the system and by the register may compromise the required consistency of the data.

Year-end quantity report

A year-end quantity report reflects quantities for a completed period. Here too, material types, masses, system and participation period must correspond to the information submitted to the system.

15 May is not the deadline for this report. That date applies to the declaration of completeness under Section 10 VerpackDG.

What applies to damaged or unsaleable packaging?

Where packaging subject to system participation is not supplied to end users because it is damaged or unsaleable, the manufacturer may request reimbursement of the participation fees from the relevant system under Section 7(3), sentence 1 VerpackDG. The condition is that the manufacturer has taken back the packaging and sent it for recovery in accordance with Section 42(5) VerpackDG.

Take-back and subsequent recovery must be documented in a verifiable form in every case under Section 7(3), sentence 2 VerpackDG. Once participation fees have been reimbursed, the relevant packaging is no longer considered to have been made available in Germany under sentence 3.

The take-back must also be reflected in the data report (Section 9(1), sentence 2 VerpackDG). A purely accounting-based reduction is not sufficient without take-back, recovery and documentation.

Data reporting and the declaration of completeness are different obligations

Data reporting under Section 9 VerpackDG reflects the information from system participation to the Central Agency Packaging Register.

The declaration of completeness under Section 10 VerpackDG must be distinguished from this. It is a separate annual declaration, which must be filed and audited by 15 May and covers packaging quantities from the previous calendar year (Section 10(1), sentence 1 VerpackDG).

Under Section 10(2) VerpackDG, it includes information on, among other things, the material type and mass of packaging subject to system participation, certain packaging not subject to system participation, participation in one or more systems, packaging taken back through industry solutions and certain take-back and recovery obligations.

Under Section 10(1), sentence 3 VerpackDG, the declaration of completeness must be audited and certified by:

• A registered expert; or

• An auditor, tax adviser or publicly appointed accountant registered under Section 56(2) VerpackDG.

The declaration and associated audit reports must be filed electronically with the Central Agency Packaging Register (Section 10(3), sentence 1 VerpackDG). The qualified electronic signature applies to the certification under Section 10(3), sentence 2 VerpackDG.

When is a declaration of completeness required?

Section 10(4) VerpackDG provides a quantity-based exemption. It refers to the following quantities of packaging subject to system participation in the previous calendar year:

• 80 tonnes of glass;

• 50 tonnes of paper, cardboard and paperboard;

• 30 tonnes of the other material types listed in Section 42(2), sentence 1 VerpackDG.

The introductory sentence and individual points of the provision are not linguistically identical. If your quantities exactly correspond to one of these values, you should therefore have the classification clarified in the individual case.

Irrespective of these thresholds, the Central Agency Packaging Register or the competent state authority may require a declaration of completeness within a reasonable deadline at any time under Section 10(4), sentence 2 VerpackDG.

Which additional obligations arise under the PPWR?

The PPWR establishes its own registration and reporting obligations alongside national obligations:

Registration in each affected Member State. Under Article 44(2) PPWR, you must register in every Member State in which you first make packaging or packaged products available, or where you unpack in the scenario under point (e) without being an end user.

No making available without registration. Under Article 44(4) PPWR, manufacturers may not first make packaging available, or unpack in the stated scenario, if they or, where applicable, their authorised representatives are not registered in the relevant Member State.

Annual register report by 1 June. Under Article 44(7) and (8) PPWR, manufacturers must submit the information specified in Part B of Annex IX PPWR to the authority responsible for the register by 1 June for each complete preceding calendar year. This report must be distinguished from the declaration of completeness due by 15 May.

Different reporting categories. Under Article 44(7) in conjunction with Annex IX, Part B, point 1(c) and Annex II, Table 1 PPWR, masses must be reported by weight according to the packaging categories in Annex II, Table 1. These categories must not be confused with the functional terms sales, grouped, primary production, transport and service packaging.

Authorised representative for extended producer responsibility. Manufacturers under Article 3(1)(15)(c) and (d) PPWR must appoint an authorised representative for extended producer responsibility by written mandate under Article 45(3) PPWR in every Member State where they first make packaging available. The Member State in which the manufacturer is established is excluded.

Establishment of the register. Under Article 44(1) and (14) PPWR, each Member State must establish the producer register within 18 months of the first implementing act under paragraph 14 entering into force. The precise reporting format and design depend on this implementing act.

What applies in the transition year 2026?

Packaging already made available. Under Section 68(5) VerpackDG, Section 10 VerpackDG applies exclusively to packaging made available in Germany during the 2026 calendar year. For the breakdown of information from 2026 in the data report under Section 9 and the declaration of completeness under Section 10, Section 3(5) of the Packaging Act and Section 16(2) and (3) of the Packaging Act apply accordingly.

Existing registrations. Under Section 68(2) VerpackDG, anyone registered under Section 9 of the Packaging Act in the version applicable until 11 August 2026 is also deemed registered under Section 6 VerpackDG. Changes under Section 6(1), sentence 2 VerpackDG must be made by 12 November 2026.

New registration obligations. Manufacturers that are required to register for the first time under Section 6(1), sentence 1 VerpackDG must do so by 12 September 2026.

We advise you on all matters relating to the VerpackDG/PPWR:

PPWR consulting

Practical checklist for your data reports

1. Manufacturer role: Does your company fall within one of the scenarios in Article 3(1)(15)(a) to (e) PPWR?

2. Unpacking: If you rely on point (e), do you unpack without being an end user, and does no other person qualify as a manufacturer under points (a) to (d)?

3. Packaging classification: Which of your packaging is subject to system participation under Section 3(6) VerpackDG?

4. Exemptions: Does an exemption under Section 11 VerpackDG apply to any packaging?

5. Service packaging: Do you use the transfer to upstream distributors under Section 7(2) VerpackDG? Remember that your registration obligation remains.

6. Industry solution: Does the system participation obligation cease under Section 8(1) VerpackDG?

7. Registration: Are you registered under Section 6 VerpackDG and have you complied with the transition periods in Section 68(2) VerpackDG?

8. System participation: Has the packaging been included in a system before making it available or before unpacking it, as required by Section 7(1) VerpackDG?

9. Confirmation: Do you have the system confirmation stating material type and mass under Section 7(1), sentence 3 VerpackDG?

10. Data reconciliation: Do the registration number, material types, masses, system and participation period match the information reported to the system under Section 9(1) VerpackDG?

11. Reporting deadline: Does the obligation to report without delay apply, or does the annual report by 1 June under Section 9(2) VerpackDG apply?

12. Documentation: Are quantity changes and take-backs documented in a verifiable manner under Section 7(3), sentence 2 VerpackDG?

13. PPWR level: Have you reviewed registration and reporting obligations under Article 44 PPWR and the potential obligation to appoint an authorised representative under Article 45(3) PPWR?

14. Declaration of completeness: How do your volumes compare with the values in Section 10(4) VerpackDG?

15. Transition year: Have you considered the special rules in Section 68 VerpackDG for 2026 data?