By Razvan Toma · Founder · Last checked 7 November 2026 · Sources linked below
Quick answer
Yes, if you fill single-use plastic food packaging or single-use cups yourself. § 60(1) VerpackDG: final distributors that fill them at the point of sale also offer the same goods in reusable packaging, including cup lids, and not at a higher price or on worse terms. Vending machines inside workplaces that are not open to the public are exempt. § 60(2): point this out with clearly visible signs in the shop, and in the media you use when you deliver. § 60(3): you take back only the reusable packaging you made available. Small businesses have an easier route; see customers' own containers. 
VerpackDG § 60
More on Who needs a representative
- I only send a few items a year to Germany. Does German packaging law still apply?
- I also sell electronics in Germany. Is that the same registration as packaging?
- Does a German representative also cover my sales to other EU countries?
- Can I avoid German packaging law by not selling to Germany?
- I am a sole trader, not a company. Can you represent me?
- Can the ZSVR act as my German authorised representative?