Take-back of B2B packaging in Germany under § 39 VerpackDG

Q: My business customer wants to return used transport packaging. What do I have to do?

Take it back free of charge. § 39(1) VerpackDG obliges producers and the distributors after them to collect used, emptied packaging of the same type, shape and size as they supplied, at the place of handover or close by, separately from other waste. With customers that are not consumers you may agree a different return place and cost arrangement. With regular deliveries, take-back can happen at a later delivery.

My business customer wants to return used transport packaging. What do I have to do?

Take it back free of charge where you handed it over, or nearby. With business customers you can agree another place and cost split (§ 39(1) VerpackDG).

Since 12 August 2026, § 5 VerpackDG, implementing Article 45(3) of Regulation (EU) 2025/40, requires a producer with no establishment in Germany to appoint an authorised representative before it first makes packaging available in Germany. Read § 5

By Razvan Toma · Founder · Last checked 7 November 2026 · Sources linked below

Quick answer

Take it back free of charge. § 39(1) VerpackDG: producers and the distributors after them collect used, emptied packaging of the same type, shape and size as they made available, at the place of actual handover or close by, separately from other waste, and take it back free of charge. With regular deliveries, take-back can happen at one of the next deliveries. With customers that are not consumers, you may agree a different place of return and cost arrangement. Not reporting this to LUCID does not end the duty; see B2B reporting. VerpackDG § 39

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My business customer wants to return used transport packaging. What do I have to do?

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