Branchenlösung: an alternative to the dual system in Germany?

Q: What is an industry solution (Branchenlösung), and can I use one instead of a dual system?

Only in a narrow case. § 8 VerpackDG lifts the dual-system duty for packaging you deliver, yourself or through intermediaries, verifiably to comparable sources such as restaurants, hotels or hospitals, if you take it back free of charge through an industry solution and have it recovered. It needs a registered expert's certificate, written confirmations from every site supplied and, from November 2027, ZSVR approval.

What is an industry solution (Branchenlösung), and can I use one instead of a dual system?

Only for packaging you verifiably deliver to comparable sources such as hotels or hospitals, take back free and have recovered (§ 8 VerpackDG).

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

Only in a narrow case. § 8(1) VerpackDG: the duty to participate in a dual system lapses for packaging you deliver, yourself or through intermediaries, verifiably to comparable sources under § 3(7), if you take it back there free of charge through an industry solution and have it recovered under § 42. § 8(3) asks for a registered expert's certificate that a collection structure exists at every site supplied, written confirmations from each site, and approval under § 22. Industry solutions may operate without that approval until 31 October 2027 (§ 68(6), (7)).

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What is an industry solution (Branchenlösung), and can I use one instead of a dual system?

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