The German Packaging Act (VerpackG) introduced Packaging as an Extended Producer Responsibility (EPR) category in Germany. 

EPR regulations compel businesses to take responsibility for the entire lifecycle of any regulated products or materials that they introduce to the market.  This is primarily enforced by requiring businesses to register and report the amount of regulated products sold, and pay a proportional contribution fee to finance waste management measures.

VerpackG requires any businesses selling packaged goods in Germany (‘producers’) to register for Packaging EPR and comply with all ongoing obligations. 

This includes both domestic and overseas businesses, including those without any physical presence in Germany but are making distance sales to German customers.

What is considered packaging?

VerpackG implements an EU-wide definition of packaging into domestic German law.  The Packaging EPR category therefore includes:

• Primary packaging

Actual product packaging – this is defined as whatever is directly used to package the product itself, such as the product box and protective materials within the box

• Secondary packaging

Additional packaging – this is any packaging that is used in addition to the packaged product in its original state.  For example, this may include shipping packaging, external protective padding etc.

It is important to note that this category is separate from the Single-Use Plastics (SUP) category which was introduced recently.  Products may fall under one or more EPR categories and businesses are advised to ensure that they are fully compliant.

Steps to ensure compliance                     

Businesses selling regulated products or materials are considered producers and must comply with their ongoing obligations. 

Producers of packaging must ensure that they have fulfilled all three obligations:

1. Registration with LUCID

One of the primary obligations for companies placing packaging on the German market is registration with the LUCID Packaging Register, which is managed by the Central Agency Packaging Register (Zentrale Stelle Verpackungsregister, ZSVR).

This register enhances transparency and helps monitor compliance. Registration is mandatory, and failure to do so is considered a regulatory offense.

Penalties can include fines and prohibition from selling goods in Germany, with enforcement from both local authorities and major online marketplaces. 

2. Enrolment with a Dual System Provider

To fulfill their recycling obligations, producers must enrol with a licenced ‘dual system’ provider – a Producer Responsibility Organisation (PRO) who is responsible for the collection, sorting, and recycling of household packaging waste. 

Enrolled businesses will need to pay a licencing fee to the PRO, as well as a contribution fee proportional to the amount of packaging they introduce to the German market.

3. Data Reporting and Contribution Payment

Registered businesses must submit an annual report to LUCID and their nominated PRO which declares the amount of packaging that they have used. 

The nature of the packaging must also be specified (e.g. paper, plastic, metal, glass), along with individual weights. Inaccurate or missing data can lead to enforcement actions, including financial penalties. 

The business must also pay a contribution fee proportional to the amount reported – the rates are usually set by the PRO.   

Enforcement by online marketplaces

Major online marketplaces such as Amazon have already implemented measures to ensure that their sellers are compliant.  This includes verifying individual product listings and checking that the seller has provided the correct EPR registration number(s) that correspond to their listings. 

As of 15 June 2025, Temu will also begin the process of verifying seller compliance with the Packaging Act.  

This means that sellers who were previously selling regulated products in 2024 will need to retroactively provide:

• A German Packaging EPR registration number
• Proof of enrolment with a licenced PRO
• Proof of payment to the PRO for the 2024 calendar year

These requirements are now also in place for businesses actively trading in 2025. 

Future outlook

Germany is preparing to harmonise its packaging regulations with the upcoming EU Packaging and Packaging Waste Regulation, which is set to come into effect in 2026.

Key measures include:

• Recyclability requirements: All packaging must meet strict recyclability criteria by 2030.
• Minimum recycled content: Specific thresholds for post-consumer recycled materials will be mandated.

This alignment is expected to elevate sustainability standards across the EU while ensuring a level playing field for all market participants.

Ongoing compliance with TBA Global

TBA Global is your one-stop-shop for compliance solutions.  We have a dedicated presence in Germany and have helped thousands of businesses ensure that they are compliant with VAT, EPR and other regulations.