§ 19 VerpackDG: ZSVR approval for producers of B2B packaging

Q: I only supply B2B packaging. Do I need an approval from ZSVR?

Yes, from 2028. § 19(1) VerpackDG requires producers of packaging not subject to system participation, typically B2B transport packaging, to be approved by ZSVR before they first make it available, unless they have transferred their responsibility for all their packaging to an approved producer-responsibility organisation (§ 22). § 68(9) lets them continue without approval until 31 December 2027.

I only supply B2B packaging. Do I need an approval from ZSVR?

Yes, from 1 January 2028: producers of non-system packaging need ZSVR approval under § 19, unless an approved organisation carries their responsibility.

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

Yes, from 1 January 2028. § 19(1) VerpackDG: producers of packaging not subject to system participation, typically B2B transport packaging, must be approved by ZSVR before they first make it available. The exception: you have transferred your responsibility for all your packaging to one or more organisations approved under § 22 and named them to ZSVR. ZSVR decides within four weeks of a complete application and asks, among other things, for adequate financial and organisational means and an insolvency-proof security (§ 19(2)). § 68(9): until 31 December 2027 you may continue without it. See B2B packaging and the deadlines dataset.

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I only supply B2B packaging. Do I need an approval from ZSVR?

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