EU packaging rules (PPWR) apply since 12 August 2026 · day 91Check if it applies to you →
PPWR · since 12 Aug 2026 · Check if it applies to you →
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Can I get the licence fee back for damaged or unsold goods?

Yes, under conditions. § 7(3) VerpackDG: if you take the packaging back and have it recovered, and document each case, the system refunds the fee.

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, under conditions. § 7(3) VerpackDG: if licensed packaging never reaches the end customer because it was damaged or unsellable, you can reclaim the participation fees from the systems once you have taken it back and had it recovered under § 42(5). Document each case in a verifiable way. After the refund, the packaging no longer counts as made available in Germany. VerpackDG § 7

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Selling in Germany?

Your German authorised representative from €149 a year: help with your LUCID registration, dual-system contract and annual report included. No setup fee.