What happens if my dual system loses its approval?

Q: What happens if my dual system loses its approval?

Your licence stops counting. § 7(4) VerpackDG: if a system's approval is revoked before the end of the period you licensed, your participation is treated as not made from the moment the revocation takes effect. You then license the remaining packaging with another approved system. ZSVR keeps the list of approved systems; see our approved-bodies dataset.

Your licence stops counting from that date. § 7(4) VerpackDG: participation is treated as not made from when the revocation takes effect, so you license again.

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

Your licence stops counting from that date. § 7(4) VerpackDG: if a system's approval is revoked before the end of the period you licensed, your participation is treated as not made from when the revocation takes effect. License the remaining packaging with another approved system. ZSVR keeps the official list; see our approved bodies dataset.

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