EPR compliance guides

Under § 9(1) VerpackG, a manufacturer of packaging filled with goods must register with the Zentrale Stelle before it places that packaging on the market, and must notify any changes to its registration data without delay. Manufacturers covered by § 7(1) sentence 1 VerpackG must declare at registration that they meet their take-back duties through one or more systems or sector solutions. They must also report their system-participation packaging data without delay under § 10(1) and file a completeness declaration by 15 May each year under § 11(1). The completeness declaration is waived only where the previous year's first-time volumes stayed below the § 11(4) thresholds, and even then the authorities can ask for one at any time. Under the VerpackDG, which replaced the VerpackG on 12 August 2026, a foreign producer without a German establishment must appoint an authorised representative. Registration itself stays with the producer. Registration breaches can be fined up to €100,000 and system-participation breaches up to €200,000.