My dual-system licence dates from before 12 August 2026. Is it still valid in 2027?

Q: My dual-system licence dates from before 12 August 2026. Is it still valid in 2027?

Not by itself. § 68(1) VerpackDG says system participations entered into before 12 August 2026 continue, unless the contract says otherwise, until 31 December 2026 at the latest. Packaging you make available from 1 January 2027 needs a participation under the VerpackDG, with your LUCID number, before you sell. If your company has no establishment in Germany, your representative concludes it.

No. § 68(1) VerpackDG: system participations entered into before 12 August 2026 run until 31 December 2026 at the latest.

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

Not by itself. § 68(1) VerpackDG: participations entered into before 12 August 2026 continue, unless the contract says otherwise, until 31 December 2026 at the latest. Packaging you make available from 1 January 2027 needs a participation under § 7(1) VerpackDG, with your LUCID number, before you sell (§ 13(1)). Without a German establishment, your representative concludes it in its own name (§ 5(3)).

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