| Who is obligated and thresholds | Under § 3(14) VerpackG, the manufacturer is the distributor who first places packaging on the market commercially, and a commercial importer into Germany is treated the same way. Under § 9(1) VerpackG, manufacturers of filled packaging must register with the Zentrale Stelle before placing it on the market. Distributors may not offer packaging from an unregistered manufacturer. Marketplace operators may not enable such offers, and fulfilment service providers may not handle such packaging (§ 9(5) VerpackG). |
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| Exemptions | Under § 11(4) VerpackG, a manufacturer need not file the completeness declaration if its first-time volumes in the previous year were below 80,000 kg of glass, 50,000 kg of paper, cardboard and board, and 30,000 kg of the other § 16(2) materials. The authorities can still demand a declaration at any time. Under § 12 VerpackG, packaging demonstrably not supplied to end consumers in Germany is excluded from that section. Reusable packaging, deposit-bearing single-use beverage packaging under § 31 and sales packaging of hazardous fillings are also excluded, but § 9 registration still applies to them. |
| Registration (steps and registry) | Registration and any later change notification must be made through the electronic system on the Zentrale Stelle's website (§ 9(3) VerpackG). The Zentrale Stelle confirms the registration and tells the manufacturer its registration number. The registration must include contact details, a person with power of representation, brand names and a declaration that all details are true (§ 9(2) VerpackG). |
| Reporting obligations and deadlines | Under Section 9(1) VerpackDG, producers must report their system-participation packaging data to the Zentrale Stelle without delay. The minimum data are the registration number, material type and mass, the system name and the participation period. Companies exceeding the volume thresholds must submit an audited declaration of completeness by 15 May each year for the previous calendar year (postponed to the next working day if 15 May falls on a weekend or public holiday). It must be audited and confirmed by an auditor registered with the ZSVR. The declaration is filed electronically with the audit reports, and the confirmation must carry a qualified electronic signature (§ 11(3) VerpackG). |
| PROs and compliance schemes | Under section 3(8) VerpackDG, a system is a producer responsibility organisation that organises the collection and return of packaging requiring licensing on behalf of producers and requires authorisation from the state authorities under section 20 VerpackDG. Manufacturers under § 7(1) sentence 1 must declare at registration that they meet their take-back duties by taking part in one or more systems or sector solutions. |
| Penalties | Failing to register, or registering incorrectly, incompletely or late, is an administrative offence under § 36(1) no. 8 VerpackG. Placing packaging on the market while not properly registered falls under no. 1. Failing to participate in a dual system can be fined up to 200,000 euros. Registration and completeness-declaration offences can be fined up to 100,000 euros. The Zentrale Stelle must promptly inform the competent Land authorities, with any available evidence, when it has concrete indications of an offence under § 36. |
Under § 3(14) VerpackG, a manufacturer (Hersteller) is the distributor who first places packaging on the market commercially. Anyone who commercially imports packaging into the area where the law applies is also treated as a manufacturer.
Under § 3(12) VerpackG, a distributor (Vertreiber) is anyone who commercially places packaging on the market. The sales method and the trade level do not matter.
Under § 3(13) VerpackG, a final distributor (Letztvertreiber) is the distributor who hands packaging to the end consumer.
Under § 9(1) VerpackG, manufacturers of packaging filled with goods must register with the Zentrale Stelle before they place that packaging on the market. The Zentrale Stelle is the foundation to be established under § 24.
Under § 3(14a) VerpackG, a manufacturer with no establishment in Germany can appoint an authorised representative (Bevollmächtigter). The representative must be established in Germany and acts in its own name to perform all of the manufacturer's duties under the law.
Under § 3(14b) VerpackG, an operator of an electronic marketplace is any person or legal partnership that runs a marketplace on which other distributors can place goods on the market in their own name.
Under § 3(14c) VerpackG, a fulfilment service provider offers distributors at least two of these services for goods it does not own: warehousing, packing, addressing and dispatch. Postal, parcel and other freight carriers do not count as fulfilment service providers.
Under § 3(8) VerpackG, packaging subject to system participation means sales and outer packaging filled with goods that typically becomes waste at private end consumers.
Under § 11(4) VerpackG, a manufacturer is exempt from the annual completeness declaration if, in the previous calendar year, it first placed on the market less than 80,000 kg of glass, less than 50,000 kg of paper, cardboard and board, and less than 30,000 kg of the other materials named in § 16(2). The Zentrale Stelle or the competent state authority can still require a declaration at any time, even below these thresholds.
Under § 11(1) VerpackG, manufacturers under § 7(1) sentence 1 must file the completeness declaration by 15 May each year. It covers packaging first placed on the market in the previous calendar year.
Under § 12 VerpackG, the provisions of that section do not apply to packaging that is demonstrably not handed to end consumers in Germany. Apart from § 9, they also do not apply to reusable packaging, deposit-bearing single-use beverage packaging under § 31, or sales packaging of hazardous-substance fillings.
Under § 11(4) VerpackG, a producer is exempt from filing a completeness declaration (Vollständigkeitserklärung) if, in the previous calendar year, it first placed on the market less than 80,000 kg of glass, less than 50,000 kg of paper, cardboard and board, and less than 30,000 kg of the other materials named in § 16(2). The thresholds apply to packaging subject to system participation.
Falling below the § 11(4) thresholds does not give permanent protection. The Zentrale Stelle or the competent Land authority may require a completeness declaration at any time, even below the thresholds.
Under § 12(1) VerpackG, the provisions of that section of the Act do not apply to packaging that is demonstrably not supplied to end consumers within the territory covered by the Act.
Under § 12(2) VerpackG, the same provisions do not apply to reusable packaging, to single-use beverage packaging subject to the deposit obligation under § 31, or to sales packaging of hazardous fillings.
The § 12(2) exclusions do not cover § 9 VerpackG. Producers of reusable, deposit-bearing or hazardous-filling packaging therefore still have to register with the Zentrale Stelle.
Hazardous fillings are those listed in Annex 2 to § 3(7) VerpackG. Examples include plant protection products approved only for professional users, and certain MDI mixtures sold in pressurised containers.
Under § 3(9) VerpackG, handing over packaging that was filled on behalf of a third party back to that third party is not 'placing on the market'. This applies only if the packaging carries solely the third party's name or brand, or both.
Under § 34(1) VerpackG, final distributors with no more than five employees in total and a sales area of no more than 80 square meters get a relief from the reusable-alternative duty in § 33(1). They may instead offer to fill goods into containers the customer brings. For deliveries, storage and dispatch areas count as sales area, and part-time staff count as 0.5 or 0.75 depending on weekly hours.
The § 33(1) duty to offer a reusable alternative does not apply to vending machines installed in companies for staff supply and not open to the public. Other vending-machine sellers may instead offer filling into customer-supplied containers under § 34(2).
Post, parcel delivery and other freight transport service providers are not treated as fulfilment service providers under § 3(14c) VerpackG.
Under § 9 Absatz 1 VerpackG, manufacturers of packaging filled with goods must register with the Zentrale Stelle before they place that packaging on the market.
The Zentrale Stelle is the foundation to be established under § 24 VerpackG. The statute names it Zentrale Stelle Verpackungsregister and sets it up as a foundation under civil law.
The first registration, and any later change notification, must be made through the electronic data processing system provided on the Zentrale Stelle's website (§ 9 Absatz 3 VerpackG).
The Zentrale Stelle sets up and operates the electronic data processing systems needed for registration under § 9 VerpackG.
The registration must give the manufacturer's name, address and contact details, including postal code, town, street, country, telephone number and the European or national tax number (§ 9 Absatz 2 Nummer 1 VerpackG).
If the manufacturer has appointed an authorised representative under § 35 Absatz 2 VerpackG, the registration must include the representative's name, address and contact details and the manufacturer's written mandate (§ 9 Absatz 2 Nummer 2 VerpackG).
The registration must also name a natural person with power of representation, give the national identification number and e-mail address (of the authorised representative where one is appointed), and list the brand names under which the packaging is placed on the market (§ 9 Absatz 2 Nummern 3 to 5 VerpackG).
The registration must break down the packaging placed on the market into packaging subject to system participation under § 3 Absatz 8, the packaging types in § 15 Absatz 1 Satz 1 Nummer 1 to 5, and single-use beverage packaging subject to the deposit obligation under § 31 (§ 9 Absatz 2 Nummer 6 VerpackG).
The manufacturer must declare that all registration details are true. Manufacturers under § 7 Absatz 1 Satz 1 VerpackG must also declare that they meet their take-back obligations through one or more systems or sector solutions, or, if they have fully passed system participation to upstream distributors under § 7 Absatz 2, that they only place already system-participating service packaging on the market (§ 9 Absatz 2 Nummer 7 VerpackG).
The Zentrale Stelle confirms the registration and tells the manufacturer its registration number. It may also issue further instructions on the electronic registration procedure (§ 9 Absatz 3 VerpackG).
Manufacturers must notify the Zentrale Stelle without delay of any change to their registration data and of any permanent end to their activity as a manufacturer (§ 9 Absatz 1 VerpackG).
Producers that are not properly registered may not make packaging available on the market in Germany, and distributors and fulfilment service providers may not supply or ship such packaging.
Under § 9 VerpackG, producers of packaging filled with goods must register with the Zentrale Stelle before they place the packaging on the market.
Changes to registration data, and the permanent end of producer activity, must be notified to the Zentrale Stelle without delay (§ 9(1) VerpackG).
The first registration and any later change notifications must be made through the electronic data processing system on the Zentrale Stelle's website. The Zentrale Stelle confirms the registration and gives the producer a registration number (§ 9(3) VerpackG).
Registration must include the producer's name, address and contact details, a person authorised to represent it, its brand names, its national identification number and email address, and a declaration that all details are true. Where an authorised representative is appointed, its details and the written appointment must also be given (§ 9(2) VerpackG).
Under § 10(1) VerpackG, producers subject to § 7(1) sentence 1 must report to the Zentrale Stelle without delay the packaging details they gave when participating in a system. The minimum data are the registration number, material type and mass of the packaging, the name of the system, and the period for which participation was made.
Changes to the data reported under § 10 VerpackG, and any take-backs under § 7(3) sentence 1, must also be reported to the Zentrale Stelle.
The material data in the § 10 report must be broken down by the material types named in § 16(2) sentences 1 and 2 VerpackG. Other materials are combined into one single figure.
Producers subject to § 7(1) sentence 1 VerpackG must file a completeness declaration (Vollständigkeitserklärung) every year by 15 May, covering the sales and outer packaging they first placed on the market in the previous calendar year (§ 11(1)).
The completeness declaration must be examined and confirmed by a registered expert, or by an auditor, tax adviser or sworn bookkeeper registered under § 27(2) VerpackG (§ 11(1)).
The completeness declaration must be filed electronically with the Zentrale Stelle together with the related audit reports. The confirmation must carry a qualified electronic signature (§ 11(3) VerpackG).
Under Section 10 VerpackDG (which corresponds to § 11 VerpackG), producers who in the previous year made available at least 80 tonnes of glass, 50 tonnes of paper, paperboard and cardboard or 30 tonnes of other materials must file a declaration of completeness by 15 May.
Under Section 11 VerpackDG (formerly § 12 VerpackG), the obligations of Sections 7 to 10 VerpackDG (system participation, data reporting, declaration of completeness) do not apply to reusable packaging in a reuse system, deposit-bearing single-use beverage packaging, or sales packaging of products containing harmful substances.
Under Section 3(8) VerpackDG, a 'system' is a producer responsibility organisation within the meaning of the PPWR, which organises the nationwide collection of packaging subject to system participation on behalf of producers and requires approval from the competent state authorities (Section 20 VerpackDG).
A system's catchment area is the whole territory of each Land in which a participating producer places packaging subject to system participation on the market.
Under Section 3(6) VerpackDG, packaging subject to system participation includes sales, grouped, primary production and transport packaging that predominantly becomes waste in private households or comparable sources of waste; shipping and service packaging are always included.
Before placing filled packaging on the market, a producer must register with the Zentrale Stelle (§ 9 Absatz 1 VerpackG). Changes to registration data and any permanent end of producer activity must be reported to the Zentrale Stelle without delay.
Initial registration and later change notifications go through the electronic system on the Zentrale Stelle's website. The Zentrale Stelle confirms the registration and tells the producer its registration number (§ 9 Absatz 3 VerpackG).
Producers covered by § 7 Absatz 1 Satz 1 VerpackG must declare at registration that they meet their take-back obligations by participating in one or more systems or sector solutions (Branchenlösungen). If they have fully transferred the system-participation duty to upstream distributors, they instead declare that they place only service packaging that is already system-participating.
A producer that is not properly registered may not place packaging on the market. Distributors may not offer such packaging for sale, electronic marketplace operators may not enable its offer, and fulfilment service providers may not handle it (§ 9 Absatz 5 VerpackG).
Producers under § 7 Absatz 1 Satz 1 VerpackG must also send the Zentrale Stelle, without delay, the packaging data they gave as part of their system participation, including at least their registration number (§ 10 Absatz 1 VerpackG).
Systems must meet recovery targets on average over the year for the packaging taking part in them. Examples from 1 January 2022 are 90 mass percent for glass and 80 mass percent for beverage cartons (§ 16 Absatz 2 VerpackG).
The Zentrale Stelle Verpackungsregister (ZSVR) calculates and publishes the systems' (provisional) market shares under section 54 (1) nos. 23 to 25 VerpackDG, which replaced the VerpackG, using a market share calculation concept agreed with the Federal Cartel Office.
Under section 51 VerpackDG, the ZSVR is financed by contributions from the operators it oversees, now including producers of packaging not requiring licensing and other producer responsibility organisations, set to cover its anticipated costs.
Under § 36 Absatz 1 VerpackG, an administrative offence (Ordnungswidrigkeit) is committed by anyone who breaches the listed duties either intentionally or negligently.
Failing to register, or registering incorrectly, with the Zentrale Stelle is an administrative offence that can be fined up to EUR 100,000.
Placing packaging on the market contrary to § 9 Absatz 5 Satz 1 VerpackG (that is, while not properly registered) is an administrative offence under § 36 Absatz 1 Nummer 1.
Distributors and operators of electronic marketplaces who offer packaging for sale, or enable it to be offered, when the producer is not properly registered commit an offence under § 36 Absatz 1 Nummer 5; fulfilment service providers who carry out the activities named in § 3 Absatz 14c Satz 1 for such producers commit an offence under Nummer 5a.
Failing to take part, or taking part incorrectly or incompletely, in a system contrary to § 7 Absatz 1 Satz 1 VerpackG is an administrative offence under § 36 Absatz 1 Nummer 3.
Failing to file the declaration of completeness (Vollständigkeitserklärung) under § 11 Absatz 1 Satz 1, or filing it incorrectly, incompletely or late, is an administrative offence under § 36 Absatz 1 Nummer 11.
Failing to submit, or submitting incorrectly, incompletely or late, the data report required by § 10 Absatz 1 Satz 1 is an administrative offence under § 36 Absatz 1 Nummer 10.
Fines of up to 200,000 euros may be imposed for failing to participate in a system.
Fines of up to 100,000 euros may be imposed for breaches of the registration requirement and of the declaration of completeness, and up to 10,000 euros for breaches of data reporting.
The authority responsible for administrative offences under § 36 is the one competent under the law of the relevant Land.
Under § 37 VerpackG, items to which an offence relates, or that were used or intended for committing or preparing it, may be confiscated, with § 23 of the Gesetz über Ordnungswidrigkeiten applying.
The Zentrale Stelle must promptly inform the competent Land authorities, with any available evidence, when it has concrete indications that an offence under § 36 has been committed.
A recycling-rate deadline falls within the review period: by 31 December 2025 at the latest, at least 65 percent by mass of the packaging waste arising in Germany must be recycled each year. This target comes from the packaging-waste objectives that the VerpackG is meant to secure under Directive 94/62/EG.
The material-specific recycling targets due by 31 December 2025 are at least 25 percent by mass for wood and at least 50 percent for aluminium and plastics.
The material-specific targets due by 31 December 2025 also require at least 70 percent by mass for ferrous metals and glass, and at least 75 percent for paper and cardboard.
To show that these targets are met, the federal government carries out the necessary surveys and informs the public and market participants.
Since 12 August 2026, a producer without an establishment in Germany that supplies packaging or packaged products directly to end users in Germany must appoint an authorised representative under the VerpackDG (Section 5). Until 11 August 2026 the appointment was voluntary under the VerpackG.
An authorised representative must itself be established in Germany. It is a natural person, legal person or partnership with legal capacity that the foreign manufacturer has instructed to perform all tasks needed to meet the manufacturer obligations, acting in its own name (§ 3 Absatz 14a VerpackG).
Registration in the LUCID Packaging Register must be done by the producer itself and cannot be handed to the authorised representative. Since 12 August 2026 this rule is in Section 5(2) VerpackDG, which replaced the VerpackG. The representative takes over the producer's other obligations.
For the obligations it takes over, the authorised representative counts as the manufacturer under the VerpackG. It performs its tasks in its own name (§ 35 Absatz 2 VerpackG).
Each manufacturer may appoint only one authorised representative. The appointment must be in writing and in German (§ 35 Absatz 2 VerpackG).
If a representative is appointed, the registration under § 9 Absatz 2 VerpackG must give the representative's name, address and contact details, together with the manufacturer's written appointment of the representative. The same national identification number and email address details must also be given for the representative.
Distributors may not offer packaging from producers who are not properly registered, and online platforms must obtain the producer's registration and self-certification (now under Section 13 VerpackDG).
Fulfilment service providers may not perform any of the activities listed in § 3 Absatz 14c Satz 1 VerpackG for packaging whose manufacturer is not properly registered. Those activities are warehousing, packing, addressing and dispatch, and a provider qualifies if it offers at least two of them for distributors in Germany.
Breaching the § 9 Absatz 5 VerpackG ban on putting packaging into circulation, on offering it for sale, or on enabling its offer for sale is an administrative offence under § 36 Absatz 1 VerpackG. The same applies to carrying out the fulfilment activities in breach of § 9 Absatz 5 Satz 3.
Under Regulation (EU) 2025/40, a seller that supplies packaged goods directly to end users in an EU country is the producer there and must register in that country.
A manufacturer with no establishment in Germany may appoint an authorised representative under § 35(2) VerpackG. The appointment cannot cover registration with the Zentrale Stelle under § 9. The representative must be established in Germany and acts in its own name. It counts as the manufacturer for the obligations it takes over. Each manufacturer may appoint only one authorised representative, and the appointment must be made in a written agreement in German. If a representative is appointed, the registration must include the representative's details and the manufacturer's written appointment.
Under § 9(5) VerpackG, marketplace operators may not enable offers of packaging from an unregistered manufacturer, and distributors may not offer it for sale. Fulfilment service providers may not perform any of the § 3(14c) activities (warehousing, packing, addressing, dispatch) for such packaging. Breaches of the registration rules under the VerpackDG can be fined up to 100,000 euros.
Not if, in the previous calendar year, they first placed on the market less than 80,000 kg of glass, less than 50,000 kg of paper, cardboard and board, and less than 30,000 kg of the other § 16(2) materials (§ 11(4) VerpackG). The Zentrale Stelle or the competent state authority can still require a declaration at any time, even below these thresholds.
Yes. The § 12(2) exclusions for reusable packaging, deposit-bearing single-use beverage packaging and hazardous-filling sales packaging do not cover § 9 VerpackG, so registration still applies.
A registered expert, or an auditor, tax adviser or sworn bookkeeper registered under § 27(2) VerpackG, must examine and confirm it. It is due each year by 15 May and covers the previous calendar year (§ 11(1) VerpackG).
Under the EU Packaging and Packaging Waste Regulation (EU) 2025/40, a producer that supplies packaged products by distance contract directly to an end user may be established in another Member State or a third country, and must appoint an authorised representative for extended producer responsibility in the Member State where the end user is located. Under Article 3(1), point (15) of Regulation (EU) 2025/40, a producer means any manufacturer, importer or distributor who, irrespective of the selling technique used, including by distance contracts, first makes packaging or packaged products available in a Member State, as set out in points (a) to (d).
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This guide is for general information only and does not constitute legal advice. It summarises the official legal texts listed above as of the "last verified" date; obligations may have changed since. Check the official sources or consult a qualified professional before making compliance decisions.
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