By Razvan Toma · Founder · Last checked 7 November 2026 · Sources linked below
Quick answer
No. § 13(3) VerpackDG: distributors may not make packaging available in Germany when its producers are not registered, or not properly registered, under § 6(1). For household packaging subject to system participation, they also may not sell it when the producers have not licensed it with a dual system under § 7(1). Doing so is an administrative offence with fines of up to €100,000 (§ 66(1) no. 8, (3)). Check suppliers in the public register; see how to check a registration. Sources (2)
VerpackDG § 13VerpackDG § 13VerpackDG § 66VerpackDG § 66
More on Who is the producer
- I sell to a German retailer that resells my goods. Am I the producer?
- I dropship to customers in Germany. Who is the producer?
- What is an industry solution (Branchenlösung), and can I use one instead of a dual system?
- Do single-use PET bottles sold in Germany need recycled content?
- Which drinks packaging is exempt from the German deposit?
- Do I have to fund packaging prevention measures in Germany?