VerpackDG: The Packaging Law Implementation Act explained simply

Some key terms change with the VerpackDG. They now originate from the EU PPWR Packaging Regulation, which the VerpackDG only supplements. Understanding the new terms makes it easier to understand your obligations, for example in relation to registration or data reporting. The most important changes at a glance:

“Placing on the market” becomes “making available in Germany”

The former term “placing on the market” is replaced by “making available in Germany”. This means that packaging is made available in Germany for the first time. This new term applies to many obligations, including registration and quantity reporting.

The definition of producer comes from the PPWR

The definition of producer is governed by the PPWR and is adopted in the VerpackDG. Producers may, for example, be businesses that make packaging or packaged products available under their own name or trademark.

Businesses that unpack packaged products may also be classified as producers under certain conditions. This depends on the specific circumstances, such as the role of the business, its place of establishment and whether another primary producer is responsible.

First distributors and distributors

The VerpackDG adds two roles:

• First distributor: any natural or legal person that first makes packaging available commercially in Germany.

• Distributor: any natural or legal person that makes packaging available in Germany, regardless of the distribution method or level of trade.

System and other producer responsibility organisation

A “system” is defined in the VerpackDG as a producer responsibility organisation. The “other producer responsibility organisation” is a new addition. It assumes producer obligations for packaging that is not subject to system participation. You can find out more in the section on packaging that is not subject to system participation.

Other adjusted terms

• Material recycling replaces the former term “material recovery”.

• Reusable packaging replaces the term “multi-use packaging”.

• Financing agreement refers to the contract for financing the Central Agency Packaging Register.

The VerpackDG applies to businesses that make packaging available in Germany. Responsibility is determined by the definition of producer in the PPWR. This definition is broader than before and covers the following groups.

Producers under the PPWR

Anyone who makes packaging or packaged products available in Germany for the first time is responsible for registration and system participation. The PPWR definition of producer distinguishes between several roles and also covers businesses that unpack packaged products.

Businesses without an establishment in Germany

Special rules apply to producers that are not established in Germany.

Producers established in another EU Member State that supply goods to Germany via distance sales must appoint an authorised representative for extended producer responsibility.

For producers from third countries, the obligation to appoint an authorised representative depends on national implementation. The specific circumstances should be reviewed carefully.

An authorised representative assumes certain obligations for the producer. This is a special rule for producers without an establishment in Germany. It does not replace the general obligation to assess the business’s own role and packaging types.

Operators along the supply chain

Not only first distributors are affected. Depending on their role, distributors, fulfilment service providers and providers of online platforms also have their own obligations. The section “Application scenarios by role” explains what this means in practice.

If you make packaging subject to system participation available in Germany, you must fulfil several obligations. The following steps show the process, from registration through to the declaration of completeness.

1. Register in the LUCID register

Before making packaging available, register in the LUCID register of the Central Agency Packaging Register. Registration must take place before making it available in Germany; for businesses that unpack packaged products, it must take place before unpacking.

2. Participate in a system

Participate in a dual system for your packaging that is subject to system participation. System participation must also take place before making packaging available or before unpacking, as applicable. You can easily arrange system participation here using our calculator.

3. Submit data reports

After system participation, data reports must be submitted. The data report includes, in particular, information on:

• registration number;

• material type;

• weight of the packaging;

• name of the system; and

• system participation period.

As a general rule, the obligated party must submit the data report itself. It cannot generally be transferred to third parties. An exception also applies here under the special authorised-representative rule for producers without an establishment in Germany.

A simplification applies to certain small quantities: if no more than 10 tonnes of packaging subject to system participation are made available per year in total, a single report submitted by 1 June of the following year may be sufficient.

4. Declaration of completeness

The declaration of completeness is an annual declaration of the packaging quantities placed on the market or made available. It must be filed annually by 15 May.

The declaration of completeness must be reviewed and confirmed by a registered expert or an approved auditor.

As a general rule, an obligation to submit a declaration of completeness arises only above certain quantity thresholds. The thresholds are:

• glass: 80 tonnes;

• paper, paperboard and cardboard: 50 tonnes; and

• other materials: 30 tonnes.

Those who remain below these thresholds are generally exempt from the obligation to submit a declaration of completeness. Other obligations, such as registration, system participation and data reporting, may nevertheless apply.

Special case: service packaging

Service packaging is only filled at the point of sale or when supplied to the final recipient. Examples include bakery bags, meal trays, takeaway coffee cups, pizza boxes and carrier bags.

If you fill service packaging and supply it to final recipients, you must generally assess whether you are required to participate in a system yourself.

The obligation to participate in a system can only be transferred to a pre-distributor if the requirements of the VerpackDG are met. Section 7(2) VerpackDG is decisive. This provision is linked to the fact that the producer is considered a producer under Article 21 PPWR. Article 21 PPWR is not, however, the independent legal basis for shifting system participation. It is relevant in determining whether a business is considered a producer under certain conditions.

If the system participation obligation for service packaging is effectively transferred to a pre-distributor, the relevant producer obligations pass to that pre-distributor to this extent. This also includes registration and data-reporting obligations. The originally obligated producer must additionally register itself in the electronic register of the Central Agency Packaging Register.

Typical scenarios may include:

• A small business purchases unbranded service packaging and, under certain conditions, places it on the market under its own name or trademark.

• A larger business purchases service packaging from abroad and makes it available under its own brand.

• A business modifies service packaging. Such modification is particularly relevant where it may impair the conformity of the packaging.

These examples do not replace an individual assessment. In particular, it is decisive whether the packaging is made available under the business’s own name or trademark and whether the requirements of the VerpackDG are met.

Packaging often passes through several stages before reaching consumers. The VerpackDG therefore ties obligations to roles. Different requirements apply depending on the role you assume. The most common cases are:

The VerpackDG has applied since 12 August 2026. Existing system participation agreements concluded before this date remain valid, but no later than until 31 December 2026.

Systems approved under the previous Packaging Act as at 11 August 2026 continue to be authorised. The condition is that the relevant system demonstrates additional requirements by 1 January 2027. These include the necessary arrangements for waste management, sufficient sorting and recycling capacities, appropriate mechanisms for self-monitoring of financial management and adequate insolvency-proof security. The competent state authority may specify a separate deadline for providing the security.

This evidence concerns the systems themselves, not the individual businesses participating in a system.

Since 12 August 2026, the definition of producer has been governed by the PPWR and the VerpackDG. Businesses should therefore check whether their role is correctly classified under the new terms.

Not all changes introduced with the VerpackDG take effect immediately. Some requirements will only apply in the coming years. You should prepare for these developments at an early stage:

• Higher recycling targets for plastics. Under the VerpackDG, higher recycling targets apply to dual systems for plastics. Systems must send 75% by mass of plastics for recycling from 1 January 2028 and 80% by mass from 1 January 2030.

  These targets are obligations of the dual systems.

• Environmental design of system participation fees. In the future, fees for system participation are to be more strongly aligned with environmental criteria. The German Federal Government may define the detailed requirements by statutory instrument. This is expected for 2027.