Packaging Act (VerpackDG): Compliance Guide for Manufacturers and Retailers

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.

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 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.

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.