PPWR, VerpackG, VerpackDG and LUCID: what applies when and what changes for registration and EPR
EU Packaging Regulation or German Packaging Act? Since 12 August 2026 the answer has been: both, but no longer the act you know. Regulation (EU) 2025/40, the PPWR, has applied directly in Germany since that day. The German Packaging Act of 2019 ceased to apply on the same day and was replaced by the Packaging Law Implementation Act (Verpackungsrecht-Durchführungsgesetz), VerpackDG for short, adopted on 13 July 2026 and promulgated in the Federal Law Gazette on 17 July 2026. The new act does not transpose the Regulation, and with a regulation it neither can nor needs to. It implements it: it organises those parts that the Regulation leaves to the Member States and in doing so retains the German structures that have been working for years, above all the LUCID packaging register, the dual systems and the deposit.
This article sorts out the three levels, shows what remains from the German Packaging Act, what the VerpackDG newly introduces, which deadlines are now running and what that means for registration, system participation and volume reporting. At the end there is a synopsis to download that assigns each section of the old act to its successor and to the corresponding article of the Regulation.
Three levels, one framework
The Regulation governs the requirements for the packaging itself and the obligations of the economic operators in the supply chain: substance limits, recyclability, recycled content, minimisation, reuse, labelling, conformity assessment and declaration of conformity, the roles from the manufacturer to the fulfilment service provider, plus the principles of extended producer responsibility, registration and the deposit systems. It applies identically in every Member State, without a national transposition act.
The VerpackDG governs what the Regulation expressly assigns to the Member States: the producer register under Article 44, the organisation of extended producer responsibility under Articles 45 to 47, the authorisation of systems and producers, collection and recovery, the deposit, the penalties under Article 68 of the Regulation and the allocation of competences. It has three parts: general provisions with supplementary definitions (Sections 1 to 3), the management of packaging and packaging waste in nine chapters (Sections 4 to 61) and a short third part on conformity assessment (Sections 62 to 65), followed by the provisions on fines and the transitional rules (Sections 66 to 68).
Under Section 6(6) VerpackDG, the Central Agency Packaging Register (Zentrale Stelle Verpackungsregister, ZSVR) is the competent authority for the register under Article 44 of the Regulation. It operates LUCID, reviews registrations, data reports and declarations of completeness, authorises systems, producers and other producer responsibility organisations, and publishes the registered producers. Market surveillance for the packaging requirements themselves, in other words for substances, labelling and the declaration of conformity, lies by contrast with the authorities competent under the law of the federal states.
What remains from the German Packaging Act
For most companies the most important thing is what does not change. The section numbering is new, the obligations are largely the old ones. The following references to the German Packaging Act relate to the version in force until 11 August 2026.
Registration remains. What used to be in Section 9 VerpackG is now in Section 6 VerpackDG: producers register with the Central Agency Packaging Register via LUCID before the first making available, with name, address, tax number, the person authorised to represent them, brand names and details of the packaging, broken down into packaging subject to system participation, the packaging covered by Section 39 and single use beverage packaging subject to a deposit. Anyone who was registered remains registered (Section 68(2)).
System participation remains. Section 7 VerpackDG carries over Section 7 VerpackG: producers of packaging subject to system participation participate in one or more systems before making it available, stating the material type, mass and registration number; the system confirms the participation. The upstream shift for service packaging to the prior distributor still exists (Section 7(2)), as do the industry solutions (Section 8, formerly Section 8).
Data reporting remains. Section 9 VerpackDG corresponds to Section 10 VerpackG: the volumes reported as part of system participation must also be reported to the Central Agency Packaging Register without undue delay, broken down by the material types in Section 42. One relief is new: anyone who in the previous year made available less than ten tonnes of packaging subject to system participation reports only once a year, by 1 June (Section 9(2)).
The declaration of completeness remains. Section 10 VerpackDG corresponds to Section 11 VerpackG, with the same thresholds: anyone who in the previous year made available at least 80 tonnes of glass, 50 tonnes of paper, paperboard and cardboard or 30 tonnes of the other material types must file an audited declaration of completeness with a qualified electronic signature by 15 May.
The exemptions remain. Like Section 12 VerpackG, Section 11 VerpackDG exempts from system participation reusable packaging in existing reuse systems, single use beverage packaging subject to a deposit, sales packaging of products containing harmful substances and packaging that is demonstrably not supplied to end users within Germany.
Take-back remains. Section 39 VerpackDG carries over Section 15 VerpackG: transport packaging and other packaging not subject to system participation is taken back free of charge at the place of handover and recovered, with annual documentation by 15 May.
The deposit remains. Section 46 VerpackDG carries over Section 31 VerpackG: at least 0.25 euros per single use beverage packaging, labelling as subject to a deposit, participation in the nationwide deposit system. The information signs "EINWEG" (single use) and "MEHRWEG" (reusable) in retail are in Section 47 (formerly Section 32), and the obligation to offer takeaway food and drink in reusable packaging as well is in Section 60, with the reliefs for small businesses in Section 61 (formerly Sections 33 and 34).
The minimum recycled content remains. Section 45 VerpackDG carries over Section 30a VerpackG: single use PET beverage bottles at least 25 per cent recycled content, and from 2030 all single use plastic beverage bottles at least 30 per cent.
And the Central Agency Packaging Register remains, now in Chapter 8 (Sections 48 to 58, formerly Sections 24 to 34), with a new source of funding: other producer responsibility organisations and producers of packaging not subject to system participation will in future also contribute to its costs (Section 51).
What the VerpackDG newly introduces
What is new are the places where the Regulation brings new terms, new roles or new tasks with it.
The terms. The German Packaging Act had one producer. The Regulation has the manufacturer, who is responsible for conformity, and the producer, who bears the extended producer responsibility. For both, the VerpackDG refers to Article 3 of the Regulation and in Section 3 only adds definitions where the Regulation leaves something open, such as for packaging subject to system participation. Its definition in Section 3(6) now expressly names transport packaging as well and is based on the overall market for packaging of the same type. From this the Central Agency Packaging Register concludes that shipping packaging to end users is subject to system participation without exception, including where the recipients are commercial. Who is the manufacturer and who is the producer is explained in Manufacturer or producer? Which role your company has under the PPWR.
The shift in the producer role. Because the producer is now determined by the domestic-first principle, system participation for retailers' own brands moves from the contract filler to the retailer, and for imports without a domestic intermediary to the first party making them available in the domestic supply chain, without any transition period. For cross-border B2B deliveries the recipient is the producer, provided it is not the end user. This is not in the VerpackDG but follows from Article 3(1)(15) of the Regulation, and the Central Agency Packaging Register gave it a binding interpretation for Germany in June 2026.
Unpacking. Anyone who unpacks packaged products without being an end user can be a producer under Article 3(1)(15)(e). The VerpackDG carries this through into registration, system participation and data reporting (Sections 6, 7 and 9).
The authorised representative for extended producer responsibility. Producers without an establishment in Germany must appoint an authorised representative with a written mandate in German before the first making available, only one, and name that representative during registration (Section 5). Registration and data reporting themselves may not be delegated to third parties.
The prohibition on making available. Section 13 prohibits producers from making packaging available or unpacking it without proper registration, and distributors from offering packaging from unregistered producers. Fulfilment service providers may not act for unregistered producers, and online platforms must obtain the producer's registration and self-certification; the Central Agency Packaging Register provides automated data matching for this purpose (Section 13(4)).
The authorisation. For packaging not subject to system participation, that is above all transport packaging, Section 19 introduces an authorisation of the producer by the Central Agency Packaging Register, with financial capability, self-monitoring, insolvency-proof security and a financing agreement, or alternatively the transfer to an authorised other producer responsibility organisation under Section 22. The Central Agency Packaging Register expects its application systems in autumn 2027; the transition period runs until 31 December 2027 under Section 68(9). The systems too are authorised under Section 20 instead of being approved as before; existing approvals are deemed to be an authorisation if the system demonstrates the additional requirements by 1 January 2027 (Section 68(11)).
Conformity. The third part of the Act is short but important in practice. Section 62 provides that a signed declaration of conformity may be kept available in German or English at the manufacturer's choice and must be translated into German at the authority's request. Sections 63 to 65 govern the notification obligations in the event of non-conformity. Everything else on the declaration of conformity is in the Regulation, see PPWR declaration of conformity: template, mandatory content under Annex VIII and instructions.
The German exemptions from the heavy metal limit value. Sections 14 to 18 continue the existing EU decisions for plastic crates and pallets made from recycled content in closed loops and for glass packaging made from secondary raw materials, until the Commission repeals them at EU level. For pallets: Does the PPWR apply to B2B? Transport packaging, pallets, stretch film and used cartons.
The sanctions. Section 66 contains in paragraph 1 the administrative offences for the national obligations and in paragraph 2 those for infringements of the Regulation. The framework is graduated: up to 200,000 euros, for example for missing system participation and the reuse targets, up to 100,000 euros, for example for registration, and up to 10,000 euros for the remaining cases, among them the documentation and labelling obligations under the Regulation. More effective than the fines are the prohibitions on making available.
The labelling. The VerpackDG does not add a labelling obligation of its own to the Regulation. Section 4 permits the material numbers under Annex 2 until 12 August 2028 and prohibits divergent numbering systems, and Section 46 governs the deposit labelling. What must go on the packaging and when: PPWR labelling obligation: what applies since 12 August 2026 and what only comes in 2028.
What falls away
Little, and most of it is absorbed into the Regulation. The substance limits and the material identification of the old Sections 5 and 6 VerpackG are now Article 5 and Article 12 of the Regulation, with the German exemptions in Sections 14 to 18. The previous definition of the producer as whoever first placed packaging filled with goods on the market has been replaced by the producer definition of the Regulation, with the consequences described for own brands and imports. The general obligation to limit packaging to what is necessary remains for a transitional period in Section 12(3) VerpackDG and will be deleted as soon as Article 10 of the Regulation applies in 2030. And the approval of the systems becomes an authorisation.
LUCID: what to do now
In practice, the transitional rules in Section 68 VerpackDG come down to six points.
Registrations continue to apply. Anyone who was registered under Section 9 VerpackG is deemed to be registered under Section 6 VerpackDG (Section 68(2)).
Changes by 12 November 2026. Anyone whose details change, in particular new brand names, the packaging types under Section 39 or an authorised representative for extended producer responsibility, must add them by that date.
New producers by 12 September 2026. Anyone who became subject to registration for the first time through the new producer definition, for instance a retailer with own brands or a recipient of cross-border B2B deliveries, had to register by that date, and in any event before the first making available.
System participations continue. Participations under the old law remain valid until 31 December 2026 at the latest (Section 68(1)). New volumes from own brands, imports and shipping packaging must be licensed additionally without delay.
The 2026 reporting year is split in two. Anyone who was a producer under the old law and is no longer one under the new law continues to report, under the new rules, the volumes placed on the market up to August; for the 2026 calendar year only the declaration of completeness under Section 10 VerpackDG applies, and an additional one under the old law is not required (Section 68(5)).
Authorisation and industry solutions until 2027. Producers of packaging not subject to system participation may make it available without an authorisation until 31 December 2027 (Section 68(9)), and industry solutions may operate without an authorisation until 31 October 2027 (Section 68(6) and (7)).
The synopsis
The table assigns the most important sections of the German Packaging Act to their successors in the VerpackDG and to the articles of the Regulation. The full synopsis, with the status and deadlines for each provision, is available to download.
| Topic | VerpackG until 11 August 2026 | VerpackDG since 12 August 2026 | Regulation (EU) 2025/40 |
|---|---|---|---|
| Producer concept | Section 3(14) | Section 3 (supplementary) | Art. 3(1)(15) |
| Manufacturer concept | not present | Section 3 (supplementary) | Art. 3(1)(13) |
| Registration | Section 9 | Section 6 | Art. 44 |
| Authorised representative for extended producer responsibility | not present | Section 5 | Art. 45(3) |
| System participation | Section 7 | Section 7 | Art. 45 |
| Industry solutions | Section 8 | Section 8 | Art. 45 |
| Data reporting | Section 10 | Section 9 | Art. 44(7) |
| Declaration of completeness | Section 11 | Section 10 | Art. 44(7) |
| Exemptions from system participation | Section 12 | Section 11 | Art. 45 |
| Take-back of transport and other packaging | Section 15 | Section 39 | Art. 45 |
| Authorisation of producers without system participation | not present | Section 19, from 1 January 2028 | Art. 47 |
| Authorisation of other producer responsibility organisations | not present | Section 22 | Art. 46, 47 |
| Substance limits | Section 5 | Sections 14 to 18 (exemptions) | Art. 5 |
| Material identification | Section 6 | Section 4, until 12 August 2028 | Art. 12, Art. 70(2) |
| Minimum recycled content in PET bottles | Section 30a | Section 45 | Art. 7 |
| Deposit | Section 31 | Section 46 | Art. 50 |
| Information obligations for single use and reusable packaging | Section 32 | Section 47 | national addition |
| Reusable alternative for takeaway | Sections 33, 34 | Sections 60, 61 | Art. 32, 33 |
| Declaration of conformity | not present | Section 62 (language) | Art. 38, 39, Annexes VII, VIII |
| Fines | Section 36 | Section 66 | Art. 68 |
The most common mistakes
- "The PPWR replaces LUCID." No. Registration with the Central Agency Packaging Register is the German implementation of the register under Article 44 and continues to apply.
- "My contract filler carries on with the licensing." For own brands, the brand owner has been the producer since 12 August 2026 and participates in a system itself.
- "We only supply B2B, so no system participation." Shipping packaging to commercial end users is subject to system participation under Section 3(6) and the interpretation of the Central Agency Packaging Register.
- "We will do the 2026 declaration of completeness the old way." For 2026, only Section 10 VerpackDG applies.
- "The declaration of conformity is a matter for the ZSVR." No. The declaration of conformity and market surveillance lie with the authorities of the federal states; the Central Agency Packaging Register checks registration, volumes and authorisation.
- "We will wait on the authorisation until the ZSVR activates the system." The right course is to check now whether you are affected at all and whether another producer responsibility organisation should take on the obligations; the deadline expires on 31 December 2027.
How Polygon One helps
Polygon One keeps the two roles of the Regulation separate for each packaging unit: the manufacturer role with conformity assessment and declaration of conformity, the producer role with the target markets from which the platform derives the registration obligations. For Germany you store your LUCID number; the platform checks the register details and reminds you of the authorised representative when a unit is made available without an establishment in Germany. From the masses per component the volume reporting emerges, broken down by the eight material types of the Central Agency Packaging Register, as a validated XML for LUCID, and a note appears when the thresholds for the declaration of completeness are likely to be exceeded.
What the platform does not do: carry out the registration in the Central Agency Packaging Register's portal, conclude system participation contracts or draw up the declaration of completeness. It holds the volumes and roles so that you can do this with your figures in minutes. If you would like to see how your packaging with both roles looks in this structure, book a demo or read more on the product page for the PPWR module.
Download the synopsis
The synopsis assigns 24 provisions of the German Packaging Act to their successors in the VerpackDG and to the articles of the Regulation, with status (unchanged, amended, new, repealed), deadline and a short explanation.
Frequently asked questions
Does the PPWR replace the German Packaging Act?
The Regulation applies directly and governs packaging and the supply chain. The German Packaging Act was replaced on 12 August 2026 by the Packaging Law Implementation Act (Verpackungsrecht-Durchführungsgesetz, VerpackDG), which governs the German organisation of producer responsibility, the register, the authorisation, the deposit and the sanctions.
Who has to register under the German Packaging Act?
Every producer within the meaning of the Regulation, in other words anyone who makes packaging available for the first time in Germany or unpacks packaged products without being an end user, registers with the Central Agency Packaging Register via LUCID before the first making available (Section 6 VerpackDG).
Who does the new German Packaging Act apply to?
To all producers, distributors, systems, producer responsibility organisations, online platforms and fulfilment service providers that deal with packaging in Germany. The packaging requirements themselves are in the Regulation and apply to manufacturers, suppliers, importers and distributors.
What obligations do producers have under the German Packaging Act?
Registration, system participation for packaging subject to system participation, data reporting, above the thresholds the declaration of completeness, take-back for packaging not subject to system participation, a deposit for single use beverage packaging, and from 2028 the authorisation for packaging without system participation.
Does my LUCID registration remain valid?
Yes. Changes must be added by 12 November 2026.
What is the difference between the EU Packaging Regulation and the German Packaging Act?
The Regulation is EU law and applies directly; it governs the requirements for packaging and the obligations in the supply chain. The Act is German law and governs how extended producer responsibility, the register and the deposit are organised in Germany.
Do I also have to register in other EU countries?
Yes, in every Member State in which you make packaging available for the first time, in accordance with the rules there. For direct deliveries to end users in other Member States you additionally need an authorised representative there.
Sources and status: Regulation (EU) 2025/40 (OJ L, 22.1.2025), Articles 3, 5, 12, 38, 39, 44 to 47, 50, 68, 70. Act of 13 July 2026 adapting packaging law and other areas of law to Regulation (EU) 2025/40, Federal Law Gazette 2026 I No 207 (17 July 2026), Article 1 Packaging Law Implementation Act, Sections 1 to 23, 39, 42, 44 to 47, 59 to 62, 66, 68, as well as Articles 4 and 6. German Packaging Act in the version in force until 11 August 2026. Central Agency Packaging Register, topic pages on own brands and imports, the distinction between manufacturer and producer, and the authorisation procedure (as of 12 August 2026). This article describes the legal position as of September 2026 and does not replace legal advice.
Let's
talk.
A no-obligation 30-minute call. We’ll show you the platform, listen to how your supply chain works, and put together a transparent quote.
Or email us directly: a.ruetjes@polygon-one.com
The booking calendar is loaded from HubSpot (Ireland) and sets cookies. It appears once you allow external content.