Packaging licence for Etsy sellers: What applies under the VerpackDG?

Why the topic is relevant for Etsy sellers

The requirements for packaging itself primarily arise from the PPWR. The VerpackDG establishes specific obligations and responsibilities for Germany, in particular:

• Registration with the Central Agency Packaging Register (Zentrale Stelle Verpackungsregister, ZSVR)

• System participation for certain packaging

• Data reporting

• The declaration of completeness

• Prohibitions on making packaging available and performing certain activities

For you as an Etsy seller, the key question is whether your packaging typically becomes waste after use in private households or comparable places of waste generation. If so, an obligation to participate in a system may apply. System participation means that you report certain packaging volumes to one or more systems.

If you are already registered: Anyone already registered under Section 9 of the previous Packaging Act is also deemed registered under Section 6 VerpackDG pursuant to Section 68(2) VerpackDG. You therefore do not have to start from scratch. However, you should still check whether the information you have provided and your reported volumes are still correct.

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

PPWR consulting

Which packaging may be affected

Different types of packaging are used for Etsy sales, including shipping boxes, mailing bags, cushioning material, adhesive tape, product packaging and grouped packaging.

Whether specific packaging is subject to system participation does not depend on the material alone. It also depends on the function of the packaging, your role under packaging law and where the packaging typically becomes waste after use.

Section 3(6) VerpackDG states that packaging subject to system participation includes sales and grouped packaging, primary production packaging and transport packaging which, based on the overall market for packaging of the same type, typically becomes waste predominantly in private households or comparable places of waste generation. The provision also lists service packaging as a separate category.

The overall market is important here: The decisive factor is not where your individual shipment ends up, but where packaging of the same type typically becomes waste in the majority of cases.

Under Section 3(7) VerpackDG, comparable places of waste generation are places that are comparable to private households in terms of the packaging waste typically generated there. The law gives examples including hospitality businesses, public administrations, barracks, hospitals and educational institutions. This list is not exhaustive.

Overview of the obligations

Registration with the ZSVR

Under Section 6(1), sentence 1 VerpackDG, manufacturers must register with the ZSVR before making packaging available in Germany for the first time or, in certain cases, before unpacking it.

Under Section 6(2) VerpackDG, registration information includes, among other things, name, address and contact details, tax or identification numbers, an email address, the authorised representative, brand names, information about the packaging, where applicable information about an authorised representative, and a declaration of accuracy. This list is only an overview; the information requested in the registration process is decisive.

If your registration data changes or you permanently cease carrying out activities as a manufacturer, you must report this without delay under Section 6(3) VerpackDG.

System participation

If your packaging is subject to system participation, you must participate in one or more systems before making it available or before unpacking it, in accordance with Section 7(1), sentence 1 VerpackDG. You must provide the material type and mass of the packaging as well as your registration number.

Data reports to the ZSVR

Under Section 9(1) VerpackDG, you must also report to the ZSVR, without delay, the information that you submit to the system as part of system participation.

If, in the previous calendar year, you made available a total of less than 10 tonnes of packaging subject to system participation, Section 9(2) VerpackDG applies. This does not eliminate the reporting obligation. Instead of submitting individual reports without delay, all information must be submitted together by 1 June of the following calendar year.

However, you should not rely on this relief permanently: Under Article 44(8), second subparagraph, and Article 44(9) PPWR, Member States may establish a lower threshold and require the information quarterly.

Declaration of completeness

Under Section 10 VerpackDG, a declaration of completeness must be filed each year by 15 May. An exemption applies below 80 tonnes of glass, 50 tonnes of paper, cardboard and paperboard, and 30 tonnes of the other material types. The ZSVR or the competent state authority may require a declaration regardless of these thresholds.

If your packaging volumes are significantly below these thresholds, the declaration of completeness will generally not be relevant for you. If your volumes increase, however, you should monitor the thresholds.

Selling from abroad to Germany

If you sell to Germany through Etsy but do not have an establishment in Germany, an additional obligation may apply. Under Section 5(2) VerpackDG in conjunction with Article 45(3) PPWR, certain manufacturers without an establishment in Germany must appoint or designate an authorised representative for extended producer responsibility before making packaging available for the first time.

Registration under Section 6 VerpackDG is excluded from this arrangement. It must be considered separately.

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

PPWR consulting

Why platforms may request evidence

Online platforms and fulfilment service providers are included in certain verification and information processes under the new framework. For this purpose, Section 13(4) VerpackDG refers to Article 45(4), first subparagraph, point (b) of Regulation (EU) 2025/40 and Article 30(1), point (d) of Regulation (EU) 2022/2065.

For you, this may mean that a platform requests your registration number or other information. However, this does not mean that Etsy is necessarily subject to the same statutory obligation in every individual case. Independently of this, platforms may impose their own contractual requirements on sellers.

What happens in the event of non-compliance?

Section 13 VerpackDG provides for prohibitions on making packaging available for manufacturers and distributors, as well as activity bans for fulfilment service providers. Under Article 44(4) PPWR, manufacturers may not make packaging available on the market for the first time if they are not registered.

In addition, Section 66 VerpackDG contains provisions on administrative fines. Specific fine amounts are not set out here.

Outlook: Further PPWR requirements

The PPWR also imposes requirements on the packaging itself. These will apply in stages at later dates:

• Packaging labelling under Article 12 PPWR. This applies from 12 August 2028 or 24 months after the relevant implementing acts enter into force, whichever is later.

• Requirements on empty space in shipping packaging under Article 24 PPWR.

• Recyclability requirements under Article 6 PPWR.

• Recycled-content requirements under Article 7 PPWR.

If you design packaging yourself or arrange for packaging to be manufactured under your own brand, the manufacturer role under Article 15 PPWR may also be relevant. This may result in further requirements, such as conformity assessment under Article 38 PPWR, technical documentation and the EU declaration of conformity under Article 39 PPWR.