Micro-enterprises, small businesses and online retail: which PPWR exemptions exist and which obligations remain

In brief

Exemptions from the EU Packaging Regulation (EU) 2025/40, the PPWR, exist only for micro-enterprises and only in four places. The Regulation has no de minimis threshold. It applies to a group of companies just as it does to a coffee roaster with four staff or an online shop that ships from the living room. Micro-enterprises under Recommendation 2003/361/EC have fewer than ten staff and an annual turnover or balance sheet total of no more than EUR 2 million; small enterprises above that have no reliefs of their own. And whoever is a producer in Germany must register in LUCID before first making packaging available in any case, because Section 6 VerpackDG has no quantity or size threshold.

• The supplier becomes the manufacturer. If a micro-enterprise has packaging made under its own name or trademark by a supplier in the same Member State, the supplier carries the product obligations. According to the Commission's FAQ, the supplier also carries the producer obligations. The German Central Agency Packaging Register takes the same view, at least for service and e-commerce packaging.
• No reuse targets up to 1,000 kilograms. A micro-enterprise that makes no more than one tonne of packaging available in a Member State in a year is exempt from all reuse targets from 2030.
• No reuse offer for takeaway under the PPWR. Germany's Packaging Implementation Act (VerpackDG) requires one anyway, since 12 August 2026, for single-use plastic food containers and single-use beverage cups.
• Single-use plastic in hospitality: Member States may exempt micro-enterprises from 2030 under narrow conditions. The VerpackDG does not do so.

Small-business status for VAT purposes, such as the German "Kleinunternehmer" under Section 19 of the VAT Act, appears neither in the PPWR nor in the VerpackDG. The German Central Agency Packaging Register treats the e-commerce packaging of online retailers as always subject to system participation. If you assemble box, tape and void fill yourself or use boxes with your own logo, you are normally manufacturer and producer at the same time.

Who counts as a micro-enterprise, and why VAT status does not

The PPWR does not define the term itself. In all six places in its enacting terms where it mentions micro-enterprises, it refers to Commission Recommendation 2003/361/EC as applicable on 11 February 2025. A micro-enterprise is an enterprise which employs fewer than ten persons and whose annual turnover and/or annual balance sheet total does not exceed EUR 2 million (Article 2(3) of the Annex to the Recommendation). The headcount is mandatory; for the money, one of the two figures is enough.

Four calculation rules decide in practice:

• Staff are counted in annual work units. Part-time and seasonal work count pro rata. Working owners and partners who engage in a regular activity in the enterprise and benefit financially from it count, apprentices do not (Article 5 of the Annex).
• The latest approved accounts apply, turnover excluding VAT. Newly established enterprises use a bona fide estimate during the financial year (Article 4(1) and (3)).
• One exceptional year changes nothing. The status is only lost or acquired once the ceilings are exceeded or undercut in two consecutive accounting periods (Article 4(2)).
• Holdings are taken into account. If another enterprise holds 25 percent or more of the capital or voting rights, the two are partner enterprises; with a majority or dominant influence they are linked. Their figures go into your own calculation (Articles 3 and 6). A subsidiary of a group is therefore rarely a micro-enterprise, even with only five staff of its own. Two online shops owned by the same majority owner and active in the same market are also linked.

VAT small-business status is not a PPWR term. Special VAT schemes for small businesses only decide whether you charge VAT. Neither the Regulation nor the VerpackDG uses them, and the "small enterprise" of the SME definition, with up to 49 staff, has no reliefs of its own either. In Germany, the VerpackDG replaced the old Packaging Act on 12 August 2026 and likewise has no exemption based on turnover. A business using such a VAT scheme is usually also a micro-enterprise, but has to check this against headcount and holdings. And even then most obligations remain, as the table further down shows.

The four reliefs for micro-enterprises

1. The supplier becomes the manufacturer

Whoever has packaging or a packaged product designed or manufactured under its own name or trademark is the manufacturer under the PPWR, even if someone else prints or fills it (Article 3(1), point (13)(a)). The manufacturer carries the product obligations: conformity assessment, technical documentation, EU declaration of conformity and the identification details on the packaging. In the second edition of its FAQ (August 2026), the Commission confirms that this also applies if a company only has a standard packaging option printed with its logo.

If the brand owner is a micro-enterprise and the supplier is established in the same Member State, the supplier is the manufacturer instead (point (b)). Only the size of the brand owner counts; whether the supplier itself is small does not matter. According to the Commission guidelines, the rule also covers reusable packaging, such as your own deposit cups.

On the supplier's location, the Regulation is not consistent. The definition in point (13) requires the same Member State. For conformity assessment, documentation and declaration under Article 15, a supplier established in the Union is enough (Article 15(12)). For importers and distributors who place own-brand packaging on the market or modify packaging in a way that affects conformity, the corresponding rule is in Article 21, second subparagraph. The German register reads the rule narrowly: if a micro-enterprise orders own-brand packaging in another EU country, it is the manufacturer itself. So if you order from a printer in Poland or Austria, agree the roles in writing with the supplier. With a supplier outside the EU, the micro-enterprise always remains the manufacturer.

And the producer obligations? The wording of the Regulation only moves the manufacturer role. Registration, EPR fees and reporting attach to the producer, and under point (15) the producer is whoever first makes the packaging available in a Member State. The Commission goes further in its FAQ: a micro-enterprise with a supplier in the same Member State is exempted from its extended producer responsibility requirements, and the role moves to the supplier. The German Central Agency Packaging Register (ZSVR), the authority for producer obligations in Germany, expressly takes the same view for service and e-commerce packaging: if the supplier of the empty packaging is in the same Member State, it is "manufacturer and producer". Only the Commission guidelines of June 2026 say that size is irrelevant for the producer role. Neither Commission document is legally binding.

In Germany, then, the supplier registers and pays the EPR fees for service and e-commerce packaging with your logo, not the micro-enterprise. The register has not said this for sales packaging you fill yourself; under the wording, you are the producer there if you are the first to make the filled goods available in Germany. Get that confirmed in writing, ideally together with a copy of the declaration of conformity your supplier, as manufacturer, now has to issue. A template letter is in the supplier declaration template. For all other packaging, such as plain shipping boxes or goods from abroad, check the role separately.

An example. A bakery with eight staff has bread bags with its logo made by a packaging wholesaler in Cologne. The wholesaler is manufacturer and producer: it issues the declaration of conformity and registers the bags with a dual system. If the bakery orders the same bags from China, it is manufacturer and producer itself and has to register in LUCID, the German packaging register. If the same bakery employs twelve people in two consecutive financial years, counted in annual work units, it is no longer a micro-enterprise and is manufacturer and producer in both cases. The basic rules for both roles are in Manufacturer or producer?.

2. No reuse targets up to 1,000 kilograms

From 1 January 2030, the reuse targets of Article 29 apply. Whoever uses transport packaging such as pallets, plastic crates, jerrycans or pallet wrapping must then use at least 40 percent of it within a re-use system, including in e-commerce (paragraph 1). For transport between your own sites or to sites of linked or partner enterprises, and for deliveries to other economic operators in the same Member State, this packaging must even be fully reusable (paragraphs 2 and 3). Final distributors of beverages must make at least 10 percent available in reusable packaging.

Exempt for a calendar year is an economic operator that made no more than 1,000 kilograms of packaging available on the territory of a Member State in that year and is a micro-enterprise (paragraph 13). A micro-enterprise with 1,200 kilograms of packaging a year is therefore not exempt. Whether the 1,000 kilogram limit refers to all packaging or only to the formats covered by Article 29, the text does not say. What is certain is that anyone below it in total is covered.

Two further rules help small shippers regardless of company size. Cardboard boxes are excluded entirely from the reuse targets for transport packaging (paragraph 4, point (d)), so the usual shipping box is not affected. And for the beverage quota, final distributors with a sales area of no more than 100 square metres are exempt (paragraph 10). In e-commerce, storage and dispatch areas count as sales area (Article 3(1), point (36)).

3. No reuse offer for takeaway under the PPWR, but under the VerpackDG

Under Article 33, final distributors in the hospitality sector that sell food or beverages for takeaway must also offer them in reusable packaging within a re-use system by 12 February 2028 at the latest, at no higher price than single-use and with a notice at the point of sale. Micro-enterprises are fully exempt, including the notice and the aim of offering 10 percent in reusable packaging from 2030 (paragraph 4).

A German takeaway gains little from this. Since 12 August 2026, Section 60 VerpackDG has required all final distributors that fill single-use plastic food containers or single-use beverage cups only at the point of sale to offer the same goods in reusable packaging as well, at no higher price than in single-use packaging. The German act has no exemption for micro-enterprises. There is only a relief in Section 61: businesses with no more than five staff and no more than 80 square metres of sales area may also meet the obligation by filling customers' own containers. Part-time staff with up to 20 hours a week count as half, up to 30 hours as three quarters, and businesses that deliver count storage and dispatch areas as sales area. From 12 February 2028, Section 60 no longer covers all single-use beverage cups, only cups made of single-use plastic (Article 4, point 5, and Article 8(5) of the Act of 13 July 2026). Under the definition in Section 3(19), these include cups made only partly of plastic, such as plastic-coated paper cups.

Article 32, by contrast, applies without any exemption: whoever sells food or beverages for takeaway in the hospitality sector must offer to fill customers' own containers by 12 February 2027 at the latest, at no higher price and with a visible notice.

4. Single-use plastic for on-site consumption

From 1 January 2030, Annex V, point 3 prohibits single-use plastic packaging for food and beverages filled and consumed on the premises of hospitality businesses. Member States may exempt micro-enterprises if it is demonstrated that doing without such packaging, or access to the infrastructure needed for a re-use system, is not technically feasible (Article 25(4)). The VerpackDG contains no such rule.

Reliefs by quantity, not by size

Some thresholds do not depend on company size but on tonnage or area. They apply to anyone below them:

• Data reports in Germany: if you made less than 10 tonnes of packaging subject to system participation available in the previous year, you report to the ZSVR not continuously but once a year by 1 June (Section 9(2) VerpackDG).
• Declaration of completeness: not required below 80 tonnes of glass, 50 tonnes of paper and board and 30 tonnes of other materials. The ZSVR or the state authority can still request it at any time (Section 10(4)).
• EU register: producers below 10 tonnes a year report only simplified data by material in the future harmonised register (Article 44(8)). The Commission expects the first report in this format by 1 June 2030.
• Deposit take-back in Germany: with less than 200 square metres of sales area, you only take back single-use beverage packaging with a deposit for the brands you carry yourself (Section 46(2) VerpackDG).

None of these thresholds exempts you from registration. Producer responsibility organisations may not place a disproportionate burden on producers of small quantities, including small and medium-sized enterprises (Article 46(5)). A right to lower fees does not follow from this expressly.

What applies to micro-enterprises without exception

The same goes for fines: in Germany, making packaging available without registration risks up to EUR 100,000, failing to participate in a system up to EUR 200,000 (Section 66 VerpackDG). There is no scale by company size.

Online retail: who is manufacturer and producer of e-commerce packaging

According to the German register, shipping boxes and mailers, including labels, tape and void fill, count as "e-commerce packaging" under the PPWR. Legally they are transport packaging used to deliver products to the end user in online sales or other distance sales (Article 3(1), point (8)). End users are not only consumers but also businesses that do not resell the product (point (23)).

In Germany, the ZSVR treats e-commerce packaging as "always" subject to system participation, even when it goes to industrial and commercial customers. What remains open in each case is who carries the obligation. The register distinguishes five cases:

1. Shipping boxes or mailers with your logo: you are manufacturer and producer, whether the supplier is in Germany or abroad. Exception: you are a micro-enterprise and the supplier of the complete packaging is in the same Member State. Then the supplier is manufacturer and producer.
2. Complete unbranded shipping packaging bought in Germany, such as boxes or mailers with an integrated adhesive strip: the producer is whoever first makes it available in the domestic supply chain, meaning the maker, importer or wholesaler.
3. You assemble box, tape and void fill yourself: the complete packaging only comes into being with you. You are manufacturer and producer.
4. You add to complete packaging, for example extra tape or void fill: if that may affect recyclability, you count as manufacturer under Article 21 and are also the producer. The same applies if you use the sales packaging itself for shipping and add something to it.
5. You ship from abroad directly to end users in Germany: you are manufacturer and producer of the e-commerce packaging, whether your company is based in another EU country or in a third country.

The Commission sees the plain standard box somewhat differently. According to its FAQ, the box maker is the manufacturer, even if the box is delivered flat and still has to be folded. A shipping label does not make anyone a brand owner. For system participation in Germany, the register's view is decisive. Who is the manufacturer, and therefore issues the declaration of conformity, is for you to assess, as the register itself says.

And the goods themselves? If you buy third-party branded goods from another EU country and sell them in Germany, you are a distributor, not an importer, and normally the producer of the sales packaging, because you are the first to make it available in the country (point (15)(b)). As a distributor you must check before selling whether the producer is registered and whether the packaging carries the manufacturer's details (Article 19(2)). Only whoever places goods from a third country on the EU market is an importer; importers have the stricter checking and labelling duties of Article 18. More on shipping boxes, film and strapping in business-to-business deliveries is in who is the manufacturer of cartons.

Shipping across borders: one representative per country

Whoever sells from one Member State directly to end users in another Member State is the producer there, for the e-commerce packaging as well as for the packaging of the goods (Article 3(1), point (15)(c) and (d)). The Regulation sets no minimum quantity. A single parcel to Vienna makes an online shop in Cologne a producer in Austria.

Article 45(3) adds to this: in every Member State you supply in this way, you must appoint an authorised representative for extended producer responsibility by written mandate, except in your own Member State of establishment. The obligation has applied since 12 August 2026. Germany implements it in Section 5 VerpackDG: foreign producers without an establishment in Germany appoint exactly one authorised representative before first making packaging available, in writing and in German. The representative takes on all obligations except registration, which stays with the producer. Producers from third countries also need an authorised representative in Germany. Under the wording of the first sentence of Article 45(3), the obligation already applies to them if they deliver directly to end users. Germany has also used the option in the second sentence (Section 5(2), second sentence, VerpackDG). How to tell the PPWR's two kinds of authorised representative apart is explained in when you need an authorised representative.

The EU declaration of conformity must be available in the language required by each country of delivery (Article 39(2)). Germany accepts German or English and requires a translation only on request of the authority (Section 62 VerpackDG). If you deliver to five countries, you may need five language versions, provided you are the manufacturer.

Marketplaces and fulfilment service providers: no registration number, no sales

Since 12 August 2026, EU law has also required online platforms and fulfilment service providers to check their sellers' registration and producer obligations. In Germany, marketplaces and fulfilment service providers already had such a duty under the old Packaging Act.

Online platforms that allow consumers to conclude distance contracts with producers, and that fall under the Digital Services Act rules for such platforms, must obtain two documents before admitting a producer. These are its registration, with registration number, in the consumer's Member State, and its self-certification that it meets its producer obligations there (Article 45(4)). The platform must make best efforts to assess whether the information is complete and reliable (paragraph 6). In Germany, the ZSVR provides an automated check against the public register for this (Section 13(4) VerpackDG). According to the register, products may not be offered on the platform without these documents. If you sell through an online marketplace, its operator may, on the basis of a written mandate, fulfil your obligation to pay the financial contributions on your behalf (Article 45(4), second subparagraph). Registration and self-certification remain your responsibility.

Fulfilment service providers that store, pack and ship for you receive your registration details and the self-certification from you when the contract is concluded (Article 45(7)). They check the information, ask for corrections if in doubt and suspend their services if nothing comes (paragraph 8). German law is stricter: they may not work for unregistered producers at all (Section 13(4) VerpackDG), with fines of up to EUR 100,000. Fulfilment service providers must also ensure that storage, packing and dispatch do not affect the conformity of the packaging (Article 20). If the provider fills the shipping boxes, the empty-space ratio applies to it as well, because Article 24 obliges whoever fills.

Small retailers should therefore store their registration number and self-certification with every platform and in every fulfilment contract before listing the first product. How registration works in Germany is explained in PPWR, VerpackG, VerpackDG and LUCID.

What 2028 and 2030 bring for mail-order retailers

Sorting label. Transport packaging is exempt from the harmonised label on material composition, but e-commerce packaging expressly is not (Article 12(1)). The label becomes mandatory from 12 August 2028 or 24 months after the implementing act, whichever is later. From the same point, the information from the label must be available in the online shop before purchase (Article 12(5)). Shipping material manufactured or imported before then may still be made available on the market until three years from the "date of entry into force" of the labelling requirements, which systematically means the start of the labelling obligation (Article 12(12)). Details are in PPWR labelling requirements.

Empty space. Whoever fills grouped, transport or e-commerce packaging must keep an empty-space ratio of no more than 50 percent (Article 24(1)). This applies from 1 January 2030 or three years after the implementing act on the calculation method, whichever is later. Void fill counts as empty space, so paper cushioning does not improve the ratio. Exempt is whoever uses the sales packaging itself for shipping and whoever ships in reusable packaging within a re-use system (paragraph 5); the sales packaging must then meet the minimisation requirements of Article 10. There is no exemption for small shippers, and for shops with changing product sizes this is the hardest point: three box sizes for thirty products will hardly be enough in 2030. How the rule is calculated is explained in Recyclability, recycled content, empty space.

Reuse. Cardboard shipping boxes are excluded from the reuse targets. Affected are plastic crates, pallets and pallet wrapping. Online retailers of beverages are also final distributors and must offer 10 percent of their beverages in reusable packaging from 2030, unless the 100 square metre rule or the exemption for micro-enterprises applies. Wine, spirits, milk and highly perishable beverages are excluded (Article 29(7)).

Deposits in mail order (Germany). Whoever ships single-use beverages with a deposit must ensure a return option at a reasonable distance from the customer (Section 46(2) VerpackDG) and show the EINWEG and MEHRWEG notices in the online shop at least as large as the price (Section 47).

Deadlines at a glance

The full timeline to 2040 is in PPWR deadlines.

How to proceed in practice

1. Check your status: staff in annual work units, turnover or balance sheet total of the last two sets of accounts, holdings of 25 percent or more. Record the result with a date.
2. List your packaging: sales, service and e-commerce packaging, void fill and tape, each with the supplier, where it is established and whether your name or logo is on it.
3. Determine the role per packaging: manufacturer, producer, distributor or importer, separately for each country of delivery. The PPWR check for your packaging helps with a first assessment.
4. Secure the supplier rule: where you, as a micro-enterprise, see the manufacturer and producer role with your domestic supplier, get written confirmation of system participation and the declaration of conformity.
5. Check LUCID (Germany): registration in place, all brand names entered, details updated by 12 November 2026, system contract for 2027 concluded.
6. Brief platforms and fulfilment: registration number and self-certification to every marketplace and every service provider, for every country you sell to.
7. Check cross-border shipping: for every country with direct shipping to end users, organise registration and an authorised representative, or deliberately stop shipping there.
8. Prepare for 2028 and 2030: check your box range against the 50 percent empty-space ratio, plan remaining stock of shipping material before the labelling obligation starts.

How Polygon One helps

Not every small business needs software for this. An online shop with five types of packaging and two suppliers can manage with a clean spreadsheet and a folder for the evidence. It gets demanding once several countries, marketplaces, suppliers and own brands come together. Polygon One assigns each packaging its manufacturer and its producer per country. Materials, quantities, suppliers and evidence sit in one data set, from which the system prepares the quantity report and the declaration of conformity under Annex VIII. Polygon One does not, however, register you in LUCID or conclude a contract with a dual system for you. We show how this looks for your range in a demo; more on the PPWR module product page.

• Download: PPWR Compass for Micro-Enterprises and Online Retailers 2026 with status check, exemptions, shipping cases, deadlines and checklist (PDF)

Frequently asked questions

Are there PPWR exemptions for micro-enterprises or small businesses?

Only for micro-enterprises and only in four places; there is no de minimis threshold. The Regulation applies regardless of size and quantity. Micro-enterprises with fewer than ten staff and no more than EUR 2 million turnover or balance sheet total get relief in only four places. These are the manufacturer role for own brands with a supplier in the same Member State, the reuse targets up to 1,000 kilograms a year, the reuse offer for takeaway and a Member State option for single-use plastic in hospitality.

Does small-business status for VAT exempt me from the PPWR and the German Packaging Act?

No. VAT schemes for small businesses, such as the German "Kleinunternehmer" rule, play no role for packaging obligations. Neither the PPWR nor the German Packaging Implementation Act (VerpackDG), which replaced the Packaging Act on 12 August 2026, uses the term. What matters is whether you are a micro-enterprise under Recommendation 2003/361/EC, and even then registration, system participation and most other obligations remain, insofar as you are the producer.

Do I have to register in LUCID as a micro-enterprise or with small quantities?

Yes, if you are a producer, meaning you are the first to make packaging available in Germany. Section 6 VerpackDG has no quantity or size threshold. Small quantities only ease reporting: below 10 tonnes in the previous year you report once a year by 1 June (Section 9(2)), and making packaging available without registration risks a fine of up to EUR 100,000. The only exception is if you are not the producer of any of your packaging, for example because you obtain only service or e-commerce packaging with your logo from a domestic supplier, which according to the German register is then the producer itself. The register does not say this for sales packaging you fill yourself; check the role separately there, because under the wording of Article 3(1), point (15)(b), the producer is whoever first makes the filled goods available in Germany.

Who is responsible for packaging with my logo if I am a micro-enterprise?

If your supplier is established in the same Member State, it is the manufacturer and issues the declaration of conformity (Article 3(1), point (13)(b)). The German register also treats it as the producer for service and e-commerce packaging. If you order outside the EU, you are the manufacturer yourself. With a supplier in another EU country the legal position is inconsistent; agree the roles with the supplier in writing.

What PPWR obligations do I have as an online retailer?

The most important ones apply regardless of company size. In Germany, e-commerce packaging is always subject to system participation according to the ZSVR, and whoever is a producer registers in LUCID before first making packaging available. Registration number and self-certification go to every marketplace and every fulfilment service provider (Article 45(4) and (7)). Whoever delivers directly to end users in other Member States is the producer there and appoints an authorised representative in each country (Article 45(3)). From 12 August 2028 at the earliest, e-commerce packaging also needs the sorting label, whose information must be available in the shop before purchase (Article 12). From 1 January 2030 at the earliest, the empty-space ratio may be no more than 50 percent (Article 24). Cardboard shipping boxes are excluded from the reuse targets.

Do online retailers have to register their shipping boxes with a system?

Yes, if you use boxes with your own logo (as a micro-enterprise only if the supplier is not in the same Member State), assemble box, tape and void fill yourself, or add to complete packaging in a way that may affect recyclability. No, if you buy complete unbranded shipping packaging in Germany and add nothing; then the producer is whoever first made it available in the domestic supply chain, meaning the maker, importer or wholesaler. This follows the view of the German register, which treats e-commerce packaging as always subject to system participation.

Am I the producer if I sell branded goods from another EU country in my online shop?

For the sales packaging, usually yes. If you buy third-party branded goods from another EU country and sell them in Germany, you are a distributor, not an importer, but you are the first to make the packaging available in the country (Article 3(1), point (15)(b)). As a distributor you also check before selling whether the producer is registered and whether the packaging carries the manufacturer's details (Article 19(2)). If the goods come from a third country, you are an importer with the stricter checking and labelling duties of Article 18.

Do I need an authorised representative if I ship to other EU countries, such as Austria or France?

Yes, if you deliver directly to end users there. You are then the producer in each country of delivery and must appoint an authorised representative for extended producer responsibility there by written mandate (Article 45(3)). There is no minimum quantity, and you do not need one in your own Member State of establishment.

What documents do online marketplaces and fulfilment service providers require from me?

Marketplaces that fall under the Digital Services Act rules for platforms obtain your registration number in the customer's country and a self-certification that you meet your producer obligations before admitting you, and check both with best efforts. Fulfilment service providers receive the same information when the contract is concluded and suspend their services if documents are missing. In Germany they may not work for unregistered producers at all.

Can the marketplace take over my packaging obligations?

Only in part. On the basis of a written mandate, the operator of an online marketplace may fulfil your obligation to pay the financial contributions on your behalf (Article 45(4), second subparagraph). Registration and self-certification remain your responsibility. According to the German register, your products may not be offered on the platform without these documents.

Does the 50 percent empty-space rule for shipping boxes also apply to small online shops?

Yes. Article 24 has no exemption by company size. From 1 January 2030, or correspondingly later if the calculation method is delayed, the empty-space ratio in e-commerce packaging may be no more than 50 percent. Void fill counts as empty space. Only whoever uses the sales packaging itself for shipping or ships in reusable packaging within a re-use system is exempt; even then the minimisation requirement of Article 10 applies.

Sources and status: Regulation (EU) 2025/40 on packaging and packaging waste, in particular Article 3(1), points (8), (13), (15), (23) and (36), Articles 5, 10, 12, 15, 18 to 21, 24, 25, 29, 32, 33, 39, 44 to 46 and Annex V. Commission Recommendation 2003/361/EC of 6 May 2003, Annex Articles 2 to 6. Commission FAQ on the PPWR, second edition (August 2026), sections II, X, XI, XIII and XVIII. Commission guidelines C(2026) 3702 of 5 June 2026, published as Commission Notice C/2026/3084, sections 2, 3 and 11. German Packaging Implementation Act (VerpackDG) of 13 July 2026, Federal Law Gazette 2026 I No 207, Sections 5 to 7, 9 to 11, 13, 46, 47, 60 to 62, 66 and 68, and Articles 4 and 8 of the Act of 13 July 2026. Topic pages of the German Central Agency Packaging Register on mail order and online retail, service packaging and the distinction between manufacturer and producer, as of 28 September 2026. This article describes the legal position as of September 2026 and does not replace legal advice.

Image credit: preview image by Rifki Kurniawan on Unsplash.