Germany

Extended producer responsibility (EPR) for packaging in Germany

Germany’s Packaging Act (Verpackungsgesetz – VerpackG) makes every company that first places sales or service packaging on the German market finance its collection and recycling. The law is enforced by the Zentrale Stelle Verpackungs­register (ZSVR), which operates the public LUCID register. Compliance with EPR Germany rules is therefore a pre-condition for selling packaged goods into the country.

Who must register for packaging EPR in Germany

All manufacturers and retailers are obligated by the provisions of the new German Packaging Act, and the regulations, therefore, apply to all who deliver packaging to Germany:

• Online shop operators, including small retailers who use sales and/or transport packaging to ship the goods sold
• Marketplace traders
• Stationary dealers
• Producers
• Importers
• Intermediaries

Ready to make extended producer responsibility effortless for Germany? Request a personalized EPR fee quote now and start turning regulatory obligations into sustainable value for your brand for cross-border sales!

What the package includes

The scheme covers every type of sales or grouped packaging that typically ends up at private households or comparable collection points, regardless of material: paper/cardboard, plastics, glass, metals (steel, aluminium), composites, wood, etc. Transport packaging that never reaches end-consumers is outside this stream.

• paper
• paper bags
• plastics
• non-returnable containers made of glass
• beverage cartons
• aluminum
• ferrous metals or other packaging based on copper
• wool
• ceramics
• wood and
• rubber

Also, the packaging includes all primary, secondary, shipping, and service packaging. Labeling note: Participation in a dual system may also require correct use of packaging symbols (e.g. the Green Dot). For practical guidance on labeling rules and symbol usage, see our Packaging Labeling Guide.

Thresholds

• No de-minimis exemption for registration or system‐participation: a single package triggers EPR packaging Germany duties.

Declaration-of-completeness thresholds (audited report due 15 May):

• 80 t glass
• 50 t paper/cardboard
• 30 t plastics + metals + composites combined

EPR registration procedure in Germany

• Register in the LUCID portal and list all brand names – this creates your public EPR number (EPR registration Germany)

• Sign a contract with a dual system (e.g., Interzero +, Der Grüne Punkt) and pre-pay recycling fees based on forecast weights

• Report packaging volumes to both the dual system and LUCID: initial forecast, ongoing monthly/quarterly updates, year-end statement by 15 May of the following year

• Keep all records for five years; ZSVR and state authorities may request them at any time

Authorized representative

Since 3 July 2021 a producer without a German establishment may appoint a Bevollmächtigter based in Germany to fulfil VerpackG obligations (registration, reporting, fee payment) in its name. The mandate must be uploaded in LUCID before the first sale.

Reporting deadline

• Ongoing volume reports – Submit either monthly or quarterly, depending on the frequency set by your dual system, for the sales period currently in progress

• Year-end volume report – For the entire previous calendar year (Year N – 1), file the report by 15 May of Year N; this requirement applies to all producers

• Audited declaration of completeness – Also due by 15 May of Year N for Year N – 1 data, but only if your volumes exceed the statutory thresholds that trigger an audit obligation

Who assumes responsibility?

• German manufacturers / packers are fully responsible as soon as a product is first placed on the German market

• Importers or intra-EU acquirers assume full liability at customs clearance or arrival—provided the packaging is not already licensed upstream

• Foreign distance sellers become liable—through a Germany-based authorised representative—when they make a direct B2C sale to a German consumer

• Dual systems (e.g., Interzero +) take on the operational duties of collection, recycling and data reporting once the membership contract is signed

• ZSVR maintains the central register and enforces compliance via data checks and audits.

Duties of each group

• Producers / importers: register in LUCID, contract a dual system, pay eco-fees, file all volume reports, and – if thresholds are met – submit an auditor-certified declaration of completeness

• Authorised representative: hold German address, maintain written mandate, carry out all VerpackG obligations on behalf of the foreign producer

• Dual systems: meet national recycling quotas, issue proof of participation, audit member data, and forward statistics to ZSVR – supporting Germany packaging recycling goals

• ZSVR / state authorities: maintain the public register, publish compliant-producer lists, and fine breaches up to €200 000 and sales bans

Stay ahead of global EPR requirements with our all-in-one compliance platform. Book a free demo today to see how easily you can register and report,whether it’s packaging, electronics, batteries, textiles, or any other regulated stream, anywhere in the world.