Does packaging of hazardous contents need a dual-system licence in Germany?

No dual-system licence, but a take-back duty. § 11 no. 3 VerpackDG lifts §§ 7 to 10 for sales packaging of contents containing pollutants (schadstoffhaltige Füllgüter). § 39(1) no. 5 requires free take-back instead. If take-back at the place of handover is not possible safely, a central collection point at a reasonable distance, open during business hours, will do (§ 39(2)). Final distributors point consumers to the return option with clear, legible signs in store and by other suitable means in distance selling. § 13(2) also ties packaging under § 39(1) to a ZSVR approval under § 19, unless an approved producer-responsibility organisation carries your responsibility; see § 19 approval. VerpackDG § 11+2