The implementation of EPR in Germany

What is Extended Producer Responsibility (EPR)?

Extended Producer Responsibility (EPR) requires producers and distributors to minimize the environmental impact of their products. This includes take-back, recycling, and disposal of products and packaging after use. In Germany, EPR implements the EU Waste Framework Directive (2008/98/EC) and aims to reduce waste, conserve resources, and promote a circular economy. Responsibility lies with companies placing products or packaging on the market, including importers and online retailers.

Packaging Act (VerpackG)

Scope

The Packaging Act (VerpackG), in effect since January 1, 2019, regulates responsibility for packaging waste generated by end consumers—such as plastic, paper, glass, metal, or composite materials. It applies to all companies selling packaged goods in Germany, whether through physical stores, online shops, or as importers. This includes shipping packaging disposed of in private households.

EPR Implementation

Producers and distributors must participate in a dual system, such as "Grüner Punkt" or other providers (e.g., Reclay, Interseroh), to ensure the collection and recycling of packaging. Since 2019, registration with the Central Packaging Register (ZSVR) has been mandatory. The ZSVR monitors compliance, publishes data via the LUCID register, and ensures transparency. Companies must pay license fees to the dual system based on packaging type and volume. The law promotes recycling through high targets, such as 63% for plastic packaging since 2022.

Obligations

• Registration: Sign up in the LUCID register before placing packaging on the market.

• System participation: Sign a contract with a dual system to finance disposal.

• Reporting: Submit regular packaging volume reports (monthly or annually) to ZSVR and the dual system.

• Recycling quota: Meet recycling rates depending on the material (e.g., 90% for glass, 80% for paper).

• Data auditing: From 2022, companies exceeding certain thresholds (e.g., 80,000 kg of glass or 50,000 kg of plastic annually) must have their reported volumes verified by an independent body.

• Fines: Violations such as failing to register or providing incorrect data may result in fines up to €200,000.

Electrical and Electronic Equipment Act (ElektroG)

Scope

The Electrical and Electronic Equipment Act (ElektroG) governs the handling of electronic devices, from household appliances (e.g., refrigerators, washing machines) to consumer electronics (e.g., TVs, smartphones) and IT equipment (e.g., laptops). It implements the EU Directive 2012/19/EU (WEEE Directive) and applies to any company placing such devices on the German market.

EPR Implementation

Manufacturers must register their devices with the Foundation for the Register of Old Electrical Devices (EAR) and establish take-back systems. They are responsible for financing the collection, treatment, and disposal of old devices. Municipal collection sites and retailer programs assist in the process. ElektroG encourages reuse and recycling to reduce hazardous substances (e.g., lead, mercury) and recover valuable materials. Since 2022, stricter requirements mandate free take-back by online retailers.

Obligations

• Registration: Register with the EAR Foundation, specifying device types and quantities.

• Take-back: Provide return options via municipal collection points or proprietary systems.

• Financing: Cover the costs of collecting, treating, and recycling old devices.

• Labeling: Devices must bear the crossed-out wheeled bin symbol and a WEEE number.

• Reporting: Submit annual reports of product quantities placed on the market to EAR.

• Retailer duties: Sellers with over 400 m² of retail space or relevant online sales must accept returns (1:1 take-back).

Battery Act (BattG)

Scope

The Battery Act (BattG) regulates all types of batteries and accumulators, including device, vehicle, and industrial batteries. It implements EU Directive 2006/66/EC. As of August 18, 2025, BattG will be replaced by the EU Battery Regulation (EU) 2023/1542 and the forthcoming Battery Law Implementation Act (BattDG), introducing new requirements.

EPR Implementation

Manufacturers and distributors must take back and recycle used batteries free of charge. They are required to join a take-back scheme, such as Stiftung GRS Batterien or other systems. BattG states that end users can return batteries to designated collection points like recycling centers or in-store drop boxes. The new EU regulation introduces stricter rules, including a digital battery passport, detailed chemical composition data, and higher recycling targets (e.g., 61% for lithium-ion batteries by 2031).

Obligations

• Registration: Sign up with the EAR Foundation or a take-back system.

• Take-back: Ensure widespread collection through retail and municipal channels.

• Recycling: Finance and organize environmentally sound battery recycling.

• Labeling: Batteries must show the crossed-out wheeled bin symbol and information on hazardous substances (e.g., “Pb” for lead).

• Reporting: Submit annual reports of battery volumes placed on the market.

• Future requirements: From 2025, manufacturers must document CO₂ footprints and recycled content.

Circular Economy Act (KrWG)

Scope

The Circular Economy Act (KrWG) is the foundation of German waste management law and promotes circular economy principles such as waste prevention, reuse, and recycling. It implements the EU Waste Framework Directive (2008/98/EC) and forms the legal basis for product-specific laws like VerpackG, ElektroG, and BattG.

EPR Implementation

KrWG obliges producers to design products to avoid waste and support resource recovery. It introduces the duty of care, encouraging companies to develop durable, repairable products. The law prioritizes material recycling over energy recovery and mandates producer take-back systems. The 2020 revision strengthened product responsibility requirements to advance circular economy goals.

Obligations

• Product responsibility: Design products for longevity and waste reduction.

• Take-back: Establish systems for collecting and recycling own products.

• Recycling priority: Material recovery takes precedence over incineration or landfilling.

• Documentation: Maintain proof of compliance with legal requirements.

• Waste prevention: Implement measures like reusable packaging.