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 →
Home / Answers

I run a small café. Can I fill customers' own containers instead of offering reusables?

Yes, with at most five employees and 80 m² of sales area. § 61(1) VerpackDG; when you deliver, storage and shipping areas count too.

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, if you are small enough. § 61(1) VerpackDG: final distributors with no more than five employees in total and no more than 80 m² of sales area may meet the § 60 duty by offering to fill goods into reusable containers the customer brings, at no higher price. If you deliver, all storage and shipping areas count as sales area. Part-time staff count as 0.5 up to 20 hours a week and 0.75 up to 30 hours. Vending machines may use the same option (§ 61(2)). § 61(3): for damage from filling customers' containers you are liable only for intent and gross negligence. § 61(4): announce the offer with clear signs, or in your delivery media. See the reusable alternative. VerpackDG § 61

More on Who needs a representative

All answers →

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.