info@ecopv-eu.com
+49 6196 5835357
info@ecopv-eu.com
+49 6196 5835357
All questions regarding LUCID registration, participation in recycling systems, the German Packaging Act (VerpackDG), the PPWR, and the placing on the market of packaging materials. This detailed guide answers your questions about the legally compliant implementation of packaging law for product, shipping, and service packaging in Germany and Europe.
Basics of the Packaging Law Implementation Act (VerpackDG) & PPWR
The VerpackG, which was valid until August 2026, required anyone supplying packaged goods to the German market to register, participate in the system (“packaging license”), and submit regular volume reports. It implemented extended producer responsibility (EPR) at the national level.
The law made a strict distinction between sales packaging from private end consumers – which was subject to system participation – and transport or industrial packaging. The central regulatory body was the LUCID Packaging Register. Contributions paid to dual systems financed nationwide collection and sorting (e.g., via the yellow bag) within Germany. With the introduction of harmonized EU rules, the Packaging Act (VerpackG) was finally repealed in the summer of 2026.
The PPWR (Packaging and Packaging Waste Regulation) is an EU regulation that took effect in phases as of August 12, 2026. It harmonizes packaging law directly across all member states and introduces uniform requirements throughout Europe for recyclability, labeling, and sustainability standards.
The regulation puts an end to the varying national regulations across Europe. The PPWR makes a legally precise distinction between the producer (responsible for packaging design and the declaration of conformity) and the manufacturer (responsible for the financial aspects of disposal and EPR reporting). It gradually bans unnecessary packaging, sets strict limits on the empty volume of shipping cartons, and prohibits the use of hazardous chemicals such as PFAS in food packaging. Foreign suppliers not based in Germany are also required to appoint a domestic authorized representative.
Yes, the old VerpackG was repealed on August 12, 2026. It was replaced at the same time by the new national Packaging Law Implementation Act (VerpackDG), which adapts Germany’s existing, well-functioning structures to the overarching EU framework with minimal bureaucracy.
Since an EU regulation is directly applicable, Germany uses the VerpackDG solely to regulate the national infrastructure. The LUCID packaging register and the licensed dual systems remain in place without restriction as central platforms. For companies, the basic obligations – registration, participation in a system, and data reporting – remain essentially the same, but are now legally based on the new law.
The VerpackDG is the German implementing law that took effect on August 12, 2026, to accompany the directly applicable EU Packaging Regulation (PPWR). It replaces the previous Packaging Act (VerpackG) and aligns national structures with the new European legal framework.
Since the PPWR is directly applicable as an EU regulation, the VerpackDG governs the national infrastructure in Germany. It ensures that the established LUCID packaging register at the Central Packaging Register (ZSVR) and the licensed dual systems continue to operate seamlessly. For companies, the proven processes of registration, system participation, and data reporting remain in place, but are now legally based on the new Packaging Law Implementation Act (VerpackDG).
The EU Packaging and Packaging Waste Regulation (PPWR) has been binding and directly applicable in all EU member states since August 12, 2026. Additional requirements will take effect on staggered dates through 2040.
As of the effective date in August 2026, the basic registration requirements, initial substance bans (such as limit values for PFAS in food packaging), and the requirement for foreign suppliers to appoint an authorized representative took effect immediately. Other requirements will be phased in gradually. For example, starting in 2030, design for recycling, mandatory minimum recycled content in plastic packaging, and strict void space requirements for shipping cartons will become mandatory.
Definition of a Producer
A producer is defined as the entity that first makes packaged products commercially available in Germany. According to the PPWR, the principle of domestic priority is decisive: the first company in the domestic supply chain is liable.
This term differs from “manufacturer,” who is liable for the packaging design and the declaration of conformity. If a company has goods packaged under its own brand, it is considered both a manufacturer and a producer under the brand principle. Importers and foreign online retailers who ship goods directly to German end consumers are also considered manufacturers and are required by law to fulfill their obligations themselves in the LUCID registry – delegating data reporting to third parties is prohibited by law.
A “producer” is any company that places packaging on the market of an EU member state for the first time on a commercial basis. This explicitly includes distance sellers who sell goods directly to end consumers in another member state, regardless of where their company is actually headquartered.
The primary goal of the PPWR is the EU-wide harmonization of extended producer responsibility (EPR). Cross-border online retailers without a branch in the EU destination country are considered producers in the end consumer’s country and are required to appoint a local authorized representative there. This regulation closes loopholes in international e-commerce. At the same time, the monitoring and liability obligations for platform operators have been tightened; they are now liable for unregistered sellers in the same way as under electrical and battery legislation.
Yes. Online retailers and marketplace sellers who ship packaged goods to private end customers in Germany are considered manufacturers. They are required to register with the LUCID packaging registry and enter into contracts with a dual system.
This requirement applies regardless of the sales channel used – whether it’s their own online store, Amazon, eBay, or Kaufland. Operators of online marketplaces are legally required to electronically verify their sellers’ LUCID numbers and to immediately and automatically block listings without valid proof. When using fulfillment service providers (e.g., FBA), the seller or brand owner remains legally responsible; the fulfillment service provider is not considered the manufacturer of the shipping packaging.
Yes. As soon as a foreign company ships filled packaging to end customers in Germany, it must register with the LUCID registry and obtain a license from a dual system. Companies not headquartered in Germany are required to appoint a domestic authorized representative for this purpose.
The German Packaging Act Implementation Act (VerpackDG) requires full compliance with EPR requirements regardless of the company’s place of business. Foreign distance sellers can no longer register directly but must appoint an authorized representative based in Germany. This representative assumes legal liability, handles data reporting, and manages participation in the system.
Types and Categories of Packaging
Packaging law distinguishes between sales packaging, outer packaging, and transport packaging. The legal obligations depend primarily on whether the packaging becomes waste in the hands of a private end-user or in a commercial setting.
Sales packaging (including shipping packaging in e-commerce) encloses the goods until they are handed over to the end user. Outer packaging bundles multiple sales units (e.g., six-packs), while transport packaging (e.g., pallets, stretch film) is used exclusively for B2B goods transport. Retail packaging is subject to the full system participation requirement for private households. Transport packaging is generated in the commercial sector; separate take-back and documentation requirements apply to it, but not the traditional dual-system licensing.
All sales and outer packaging that, according to typical legal practice, ends up as waste at private end-user households or equivalent collection points (e.g., restaurants, hospitals) is subject to mandatory participation in a recycling system. Manufacturers must obtain a license for a dual system to cover these quantities.
The license fee covers the costs of curbside collection, sorting, and recycling. Typical examples include food packaging, shipping boxes, cosmetic jars, and packing materials used in online retail. Pure B2B transport packaging is exempt from participation in the dual system. The fee amount is calculated individually based on material type and weight.
Service packaging refers to packaging that is filled with goods only immediately at the point of delivery to the end consumer (e.g., pizza boxes, coffee cups, or bakery bags). It is generally subject to participation in the recycling system but offers administrative simplification during the purchasing process.
The final distributor (e.g., a restaurant owner or baker) can purchase pre-licensed service packaging from a wholesaler, whereby the upstream supplier covers the financial licensing fees for the dual system. This pre-licensing must be fully documented on the invoice. Important: The obligation to register independently in the LUCID Packaging Register with the Central Agency for Packaging Registers (ZSVR) remains non-transferable and rests with the final distributor, who must carry it out on their own. If unlicensed raw materials are purchased, the final distributor also becomes the initial distributor and must handle all data reporting and system fees entirely on their own. To do so, they must enter into a contract with a dual system and report packaging weights broken down by material type (e.g., paper, plastic).
No. Pure B2B transport packaging (e.g., pallets, stretch film, outer cartons) is exempt from participation in the traditional dual system. Disposal is handled independently through commercial take-back systems.
Manufacturers and distributors must establish a free return system for commercial packaging for subsequent distributors and document the quantities internally. Since July 2022, the ZSVR’s LUCID packaging registry has required comprehensive registration for transport packaging as well. However, they are not required to continuously report quantities to LUCID; the documentation must, however, be submitted upon request by the authorities. If such packaging is nevertheless handed over to a private end consumer in the course of direct sales, the law retroactively classifies it as sales packaging, thereby immediately making it fully subject to the recycling system.
B2C packaging becomes waste at private end-user households or equivalent generation points and is subject to the dual-system participation requirement. B2B packaging circulates exclusively in commerce or industry and instead requires commercial take-back logistics.
The distinction is determined by the location where the waste typically arises, not by the contractual B2B customer relationship. For packaging of products that can be used in both commercial and household settings (dual-use packaging), the ZSVR classifies it entirely (100%) as B2C goods if there is no clear B2B classification. With the PPWR having taken effect in August 2026, the “domestic priority” principle now applies: The obligation always falls on the first company to initiate the domestic supply chain by placing the product on the market. In the case of mixed distribution channels, strictly separate volume reporting is mandatory.
LUCID Register & Dual Systems
The LUCID number is the official registration number issued by the Central Agency for Packaging Registers (ZSVR). Every company that commercially supplies packaged goods to the German market must apply for this number before making its first sale.
The number serves as transparent proof of legality in e-commerce and is available for viewing in the public manufacturer directory. It is a mandatory requirement for entering into a valid license agreement with a dual system. Online marketplaces such as Amazon or eBay verify the LUCID number fully automatically.
Registration is done entirely online and free of charge via the online portal of the Central Packaging Register (ZSVR). After entering your company information, tax ID, and the brand names you use, your LUCID number will be issued immediately.
Compared to WEEE applications, the process is straightforward. However, it is important that all brand names used – without exception – be entered exactly as they appear in the portal, since the registration is legally valid only for the brands listed there. Since August 2026, foreign distance sellers without a German branch have no longer been permitted to complete the registration themselves; instead, they are required to appoint an authorized representative based in Germany. Regardless of this, once the number is received, the fee-based volume licensing process with the dual system must be completed.
A dual system is a state-approved, privately operated waste management company. It organizes and finances the collection, sorting, and recycling of B2C sales packaging from households on behalf of the business community.
Manufacturers pay a license fee (“packaging license”) to the selected system, based on material and weight. These contributions fund the operation of the yellow bin, the yellow bag, and glass and paper recycling programs. Since it is impossible for individual companies to establish their own nationwide collection infrastructure, participation in a dual system is required by law. Mere registration in the LUCID registry is not sufficient; without an active license agreement, a strict distribution ban applies.
The declaration of completeness is the final, official annual reconciliation of the actual quantities of packaging placed on the market. Larger manufacturers are required to have this report certified by a registered, independent auditor (e.g., a certified public accountant) and submit it via the LUCID portal.
This requirement applies as soon as a company has exceeded at least one of the following volume thresholds in the preceding calendar year: 80 metric tons of glass, 50 metric tons of paper/cardboard, or 30 metric tons of lightweight packaging (plastics, metals, composites). The audit prevents fraud and free-riding in the market. The submission deadline is May 15 of the following year.
Smaller operators below the thresholds are exempt from the external audit requirement.
In Germany, there are several competing dual systems to choose from. Since all providers are legally required to guarantee the same waste disposal services, the choice is primarily based on the individual licensing fees for your specific mix of materials and the scope of digital services offered.
Companies should request quotes, as the per-kilogram prices for plastics, cardboard, or glass vary significantly between the systems. For e-commerce businesses, it is important to have interfaces that automatically transfer monthly sales data from the inventory management system to the dual system and to the LUCID registry. Switching providers is generally possible at the end of the year, provided notice periods are observed; seamless transition licensing is absolutely essential in this process.
PPWR Requirements (Design, Recycling, Reusability)
Effective January 1, 2030, the PPWR mandates binding minimum percentages of recycled material (post-consumer recycled content) for nearly all plastic packaging. The initial quotas range from 10 to 35 percent, depending on the type of packaging, and will continue to rise through 2040.
The quotas depend strictly on the scope of application: For food-contact packaging made from plastics other than PET (e.g., food wrap), a 10 percent quota will apply starting in 2030. For PET beverage bottles, a 30 percent requirement will apply starting in 2030, while for other plastic packaging (e.g., shipping bags or PV module protective films), a minimum content of 35 percent is mandated immediately. Medical devices and sensitive laboratory packaging are permanently exempt.
The PPWR limits the maximum allowable empty space in transport, transit, and shipping packaging to no more than 50 percent. This requirement will become mandatory for all distributors on January 1, 2030.
The regulation prohibits shipping products in oversized boxes with unnecessary filler material (such as bubble wrap or polystyrene chips), as fillers are legally considered empty space. The ratio of empty space to the actual volume of the goods is calculated using a standardized formula. Exceptions apply only to verifiable technical protection requirements (e.g., highly sensitive solar components or fragile glass). For online retailers, this means a mandatory shift toward customized, adaptive packaging sizes (“right-sizing”) to avoid hefty fines as the PPWR is implemented at the national level.
The PPWR will ban a number of specific single-use plastic packaging items classified as environmentally unnecessary, effective January 1, 2030.
These include micro-packaging in the hotel and hospitality industry, as well as certain fresh-food packaging in supermarkets.
The ban covers miniature packaging for cosmetics and hygiene products in the lodging sector (e.g., shampoo bottles or lotions under 50 ml or 50 g) as well as single-use plastic portion packs for sauces, sugar, or coffee creamer when consumed on-site in restaurants. Also prohibited are ultra-lightweight plastic carrier bags for loose, unprocessed fruits and vegetables, unless they are absolutely necessary for hygiene reasons or to prevent food waste. In addition, plastic packaging (such as films, nets, and trays) for fresh fruits and vegetables weighing less than 1.5 kilograms, as well as shrink wrap for suitcases at airports, will be banned.
Stricter rules will also apply to e-commerce as of this effective date: shipping and outer packaging may then contain no more than 50 percent empty space to prevent unnecessary double packaging and deceptive packaging that serves no logistical protective function. By the 2030 deadline, supply chains in the affected sectors must have fully transitioned to reusable systems or plastic-free, paper-based alternatives.
Effective January 1, 2030, the PPWR mandates binding reusable packaging targets for transport packaging in the B2B sector, as well as for certain beverage and foodservice packaging. These targets will increase gradually through 2040.
In commercial goods transport (B2B), at least 40 percent of the transport packaging used (such as pallets or crates) must be reusable packaging starting in 2030. If the transport takes place within the same company or between partner companies in the same member state, a 100-percent quota applies.
For B2C e-commerce, a 40 percent reusable packaging quota will also apply starting in 2030, while a starting quota of 10 percent is mandated for outer packaging in wholesale and retail. Cardboard boxes and cardboard packaging are exempt from these reusable packaging quotas, as the requirements in this segment are primarily aimed at single-use plastics. As industries heavily dependent on B2B transportation, solar and electronics distributors in particular must transition their supply chains to durable deposit or return systems by the deadline.
The PPWR introduces an EU-wide harmonized labeling system. A standardized pictogram system makes the type of material and the correct disposal method immediately recognizable to consumers throughout Europe.
The new system puts an end to the conflicting national labeling requirements of individual EU member states, which often led to cease-and-desist letters in cross-border e-commerce. Packaging must be printed with standardized symbols that visually match the logos on public trash bins exactly. In addition, starting in February 2029, a QR code will be mandatory for reusable packaging, which will provide access to digital proof of the material’s life cycle. For manufacturers, this means they must update all print templates within the statutory transition periods, which take effect for material labeling as early as August 2028.
Starting January 1, 2030, a strict ban on non-recyclable packaging will take effect in the EU. As of this date, only packaging that meets the strict “Design for Recycling” criteria may be placed on the market.
To this end, packaging will be rated according to EU-wide performance classes ranging from A to E. If a piece of packaging does not achieve at least Class C, it will lose its market authorization on the effective date; Classes D and E will be banned. Criteria for the evaluation include, among other things, the ease with which labels can be removed, the avoidance of dyes that interfere with recycling, and the prohibition of multilayer material combinations that clog modern sorting facilities.
Under the Packaging Law Implementation Act (VerpackDG), the dual systems link their licensing fees to these classes: Environmentally beneficial packaging is financially rewarded through modulated fees, while materials that are difficult to recycle are subject to penalty fees.
Authorized Representative & International Trade
An Authorized Representative for Packaging is a person or company based in the respective EU destination country that, on behalf of a foreign manufacturer, legally fulfills the manufacturer’s packaging obligations in that country. As of August 12, 2026, this designation by the PPWR is legally mandatory for all cross-border distance sellers without a registered office in the destination country.
Anyone who delivers goods directly to private end consumers in another EU country without maintaining their own branch there may no longer sell without an authorized representative. The authorized representative handles registration in the destination country, ongoing data reporting, and contracts with the local waste disposal and recycling systems.
We already successfully provide this statutory service for the ElektroG and BattDG, and under the new VerpackDG, we also fully assume this role for your packaging volumes.
No. The LUCID registry is a purely national platform operated by the German Central Agency for Packaging Registration (ZSVR). It applies exclusively to the German market; separate country- or state-specific registrations must be completed for each additional EU destination country.
Although the PPWR harmonizes technical packaging standards across Europe, the administrative infrastructure remains decentralized. Anyone who ships across borders to multiple EU countries must register with the locally responsible registries in each individual country and pay country-specific fees. There is no central, Europe-wide packaging registry. To minimize this massive bureaucratic coordination effort, we consolidate your European EPR reports across countries into a single system.
The PPWR drastically regulates cross-border e-commerce: Distance sellers must appoint an authorized representative in every EU destination country where they do not have their own branch. At the same time, uniform European standards regarding packaging sizes, empty space limits, and labeling must be strictly adhered to.
The regulation puts an end to the era of unregulated gray areas in international online commerce. Thanks to the requirement for a local authorized representative, authorities can now directly impose sanctions on violations abroad across national borders. In the long term, however, this harmonization brings significant advantages, as standardized packaging designs with uniform pictograms can be printed for the entire EU. In the short term, the system change requires retailers to conduct a thorough review of their supply chains to prevent automated account suspensions on e-commerce marketplaces.
Sanctions & Marketplace Monitoring
Anyone who places packaging on the market without a valid LUCID registration or without an active contract with a dual system is subject to an immediate legal ban on distribution. In addition, they face severe regulatory penalties and retroactive additional charges.
The Central Packaging Register (ZSVR) automatically verifies the data. In the event of discrepancies, it initiates fine proceedings. For unlicensed companies, the authorities retroactively estimate the packaged quantities based on sales data – free-riders must pay the full amount of the system fees they saved. In e-commerce, an incorrect registration leads to the immediate suspension of seller accounts, as the platforms exclude any liability on their part.
Violations of the Packaging Act Implementation Act (VerpackDG) and the PPWR – such as failure to register, failure to participate in a recycling system, or reporting incorrect quantities – are punishable by fines of up to 200,000 euros.
The exact amount of the fine is determined by the duration of the violation and the economic benefit derived from it. Packaging quantities intentionally underreported are classified by the authorities as willful fraud, which entails criminal consequences. In addition to the fine, the company faces reputational damage that could threaten its very existence and the permanent loss of marketplace sales rights. Proactive, voluntary reporting of errors through us is generally viewed much more favorably by the authorities than a violation uncovered through audits.
Yes. Major online marketplaces such as Amazon, eBay, and Kaufland are legally required to thoroughly verify the LUCID registration number of all commercial sellers. Listings without a verified number are immediately and automatically blocked.
Although e-commerce platforms are not directly liable for sellers’ disposal fees under the Packaging Act, they are subject to a strict ban on the sale of unlicensed goods. To avoid hefty fines themselves, the platform systems electronically cross-check the number stored in the seller’s account against the ZSVR’s public registry. If the company name, tax ID number (VAT ID), or registered trademarks do not match exactly, the listing is blocked. Even a brief gap in coverage – for example, due to an improper transition from the dual system at the turn of the year – leads to an immediate account suspension.
Practical Considerations & Special Issues
There is no flat-rate fee. Costs are calculated on a case-by-case basis depending on the type of material and the exact weight of the packaging placed on the market each year, as well as the rates set by the selected dual system.
Easily recyclable materials such as paper, paperboard, cardboard, or glass are significantly less expensive to license than composite materials or plastics. The VerpackDG provides financial incentives for eco-friendly packaging design: Packaging that achieves a high recycling class according to the new EU criteria (“Design for Recycling”) benefits from reduced fees. Materials that are difficult to recycle, on the other hand, are subject to penalty fees. Larger companies must also budget for the costs of external audits of their annual declaration of completeness.
Yes, this is permitted within the framework of the statutory transition periods, provided they were already filled or shipped before the effective date.
Existing packaging stocks that can be proven to have been manufactured and placed on the market before August 12, 2026, are protected under grandfathering provisions and may be used up – unless they fall under a specific immediate ban, such as the one for PFAS in food packaging. However, this protection does not apply to empty existing stock in your own warehouse that is filled only after the effective date: Just like new production, they must fully comply with the current PPWR criteria, including the declaration of conformity, effective immediately. Once the respective substance- and material-specific transition periods have expired, non-compliant existing stock may no longer be used; otherwise, distribution bans may be imposed on the entire packaged product.
Yes. Any introduction of new packaging materials, additional brands, or a significant deviation from the projected volumes must be reported immediately to the LUCID registry and to the Dual System.
An outdated database is legally considered an incomplete volume report and is subject to penalties as an administrative offense. For example, if a company introduces a new product line with plastic blister packs, even though only cardboard packaging had been reported previously, a compliance gap will arise without an update. In the event of sharp increases in sales during the year, volume forecasts must be actively adjusted upward in the portal to avoid end-of-year back payments or fines for underreporting that could threaten the company’s existence.
ECOPV-EU as a Partner
As a specialized full-service EPR provider based in Eschborn, we handle all administrative and operational aspects of the new VerpackDG and PPWR for manufacturers, importers, and e-commerce retailers.
We guide your company through the LUCID registry in full compliance with the law, determine the optimal rates for the dual systems, and manage the ongoing monthly reporting process in sync with your ElektroG and BattDG obligations. Since the PPWR requires a domestic presence for cross-border trade, we assume the legally mandated role of authorized representative for foreign market participants without a German branch. We consolidate all of your European EPR compliance into a single, legally compliant interface.
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