Do I have to print material identification codes on my packaging for Germany?

Q: Do I have to print material identification codes on my packaging for Germany?

Not under German law. § 4 VerpackDG says packaging can be marked with the numbers and abbreviations in Annex 2 to identify its material. The marking is voluntary, but if you use it, you may not use other numbers or abbreviations for the same materials. The EU labelling rules of the PPWR apply separately.

Optional. § 4 VerpackDG lets you mark packaging with the codes in Annex 2; if you mark the material, only those codes are allowed.

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 under German law. § 4 VerpackDG: packaging can be marked with the numbers and abbreviations in Annex 2 to identify its material. If you mark it, use only those codes: other numbers or abbreviations for the same materials are not allowed. The EU labelling requirements of the PPWR apply separately; see our PPWR page. VerpackDG § 4

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