By Razvan Toma · Founder · Last checked 7 November 2026 · Sources linked below
Not if a working reuse system exists. § 11 no. 1 VerpackDG: §§ 7 to 10, meaning system participation, data reports and the declaration of completeness, do not apply to producers of reusable packaging whose actual return and reuse an existing reuse system makes possible. Reusable packaging under Article 11 PPWR falls under the free take-back duty of § 39(1) no. 6 instead. Registration in LUCID still applies (§ 13(1)). § 13(2) also ties packaging under § 39(1) to a ZSVR approval under § 19, unless an approved producer-responsibility organisation carries your responsibility; see § 19 approval. Sources (3)
VerpackDG § 11VerpackDG § 11VerpackDG § 39VerpackDG § 39VerpackDG § 13VerpackDG § 13
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