By Razvan Toma · Founder · Last checked 7 November 2026 · Sources linked below
Quick answer
A yearly record, due by 15 May. § 39(3) VerpackDG: producers and distributors that take back non-system packaging, such as B2B transport packaging, pass it to reuse or recovery under § 42(5); returning it to the previous distributor also counts. By 15 May each year they document, in verifiable form and by material type and mass, what they made available in Germany in the previous year and what they took back and recovered. They set up self-checks for accuracy and show the record to the competent Land authority on request. If you transfer your responsibility to an approved organisation, tell ZSVR electronically without delay. See B2B take-back. 
VerpackDG § 39
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