VerpackG
Anyone placing packaging on the German market for the first time must comply with the German Packaging Act (VerpackG). Here is an overview of the key obligations – and what changes on 12 August 2026 with the new EU Packaging Regulation.
Important from 12 August 2026
VerpackG is being replaced by the PPWR & VerpackDG
On 12 August 2026, the EU Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) enters into direct application and is complemented by Germany’s Packaging Law Implementation Act (VerpackDG), which sets out the national framework. The VerpackDG was published in the Federal Law Gazette on 17 July 2026, after being passed by the Bundestag (11 June 2026) and approved by the Bundesrat (10 July 2026).
The core obligations – registration, system participation and data reporting – remain in place. What changes is who is responsible in each case: the PPWR distinguishes between “manufacturers” (responsible for packaging conformity) and “producers” under extended producer responsibility (responsible for registration, reporting and financing recycling).
Obligations
The key obligations under VerpackG
LUCID registration
Before placing any packaging on the market, registration in the LUCID Packaging Register run by the Central Agency Packaging Register (ZSVR) is mandatory – since the 2022 amendment, for all packaging types, with no minimum quantity.
System participation
Sales and shipping packaging that typically ends up as waste at private end consumers must be licensed with a dual system.
Data reporting
Volumes licensed with a dual system must additionally be reported electronically to the LUCID register (Section 10 VerpackG).
Declaration of completeness
Above certain annual thresholds (incl. 80 t glass, 50 t paper/cardboard or 30 t other materials), an annual declaration of completeness under Section 11 VerpackG is also required.
Consequences
Fines for non-compliance
Missing registration or missing system participation can result in fines of up to €200,000 as well as an immediate ban on distributing the affected packaging.
PPWR outlook
What else changes from 12 August 2026
Authorised representative for foreign producers
Companies without a branch in Germany that ship packaging directly to end consumers in Germany will be required to appoint an authorised representative from 12 August 2026 – previously this was voluntary.
Authorisation procedure for packaging outside system participation
Packaging not subject to system participation will additionally require authorisation from the ZSVR. As a transitional rule, producers may operate without this authorisation until 31 December 2027, and other producer responsibility organisations until 31 October 2027.
Split calculation for the 2026 reporting year
For the 2026 declaration of completeness, companies must calculate volumes separately for the periods before and after 12 August 2026 and combine them in a single declaration.
Note: This page provides general guidance and does not replace legal advice. Whether and to what extent the obligations described apply to your company depends on your specific situation. For binding information, contact the Central Agency Packaging Register (ZSVR) at verpackungsregister.org or your legal counsel.
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