By Razvan Toma · Founder · Last checked 7 November 2026 · Sources linked below
Up to €200,000, depending on the breach. § 66(3) VerpackDG: failing to participate in at least one dual system (§ 66(1) no. 3) carries up to €200,000. Not registering correctly in LUCID (no. 1), a missing declaration of completeness (no. 6) and making packaging available while unregistered (no. 8) carry up to €100,000. Remaining offences, such as missing data reports (no. 7) or not reporting changed details (no. 2), carry up to €10,000. Acting negligently is enough. Every tier is in our deadlines dataset. 
VerpackDG § 66
Penalties for selling packaging in Germany without LUCID registration
Selling without a LUCID registration is usually not one offence but two or three at once. Not being registered is an offence under § 66(1) no. 1 VerpackDG. Making packaging available while unregistered is a second one, under no. 8, because § 13(1) forbids it. If the packaging was also never licensed with a dual system, no. 3 adds the highest tier. The table lists every offence in § 66(1) that a seller of packaged goods can commit, with the ceiling § 66(3) sets for it.
| What went wrong | Rule broken | § 66(1) | Fine up to |
|---|---|---|---|
| Not registered in LUCID, or not correctly, completely or in time | § 6(1) sentence 1 | no. 1 | €100,000 |
| A change to your registration data not reported, or late | § 6(1) sentence 2 | no. 2 | €10,000 |
| Household packaging not licensed with at least one dual system, or not in time | § 7(1) sentence 1 | no. 3 | €200,000 |
| Declaration of completeness not filed, or not correctly or in time | § 10(1) sentence 1 | no. 6 | €100,000 |
| Data report to ZSVR missing, wrong or late | § 9(1) and (2) | no. 7 | €10,000 |
| Packaging made available while unregistered or unlicensed | § 13(1) to (3) | no. 8 | €100,000 |
| A fulfilment service provider handling goods of an unregistered producer | § 13(4) sentence 1 | no. 9 | €100,000 |
All of these apply whether you acted intentionally or negligently: § 66(1) opens with vorsätzlich oder fahrlässig. Not knowing the rule is no defence, though negligence lowers the ceiling (see below).
VerpackDG § 66 VerpackDG § 6 VerpackDG § 7 VerpackDG § 13
Breaches of the EU Packaging Regulation itself
§ 66(2) VerpackDG makes breaches of Regulation (EU) 2025/40 (PPWR) fineable in Germany too. Most of them carry the lowest ceiling; the reuse targets, platform and fulfilment checks and official orders carry more.
| PPWR breach | Article | § 66(2) | Fine up to |
|---|---|---|---|
| Packaging placed on the market that misses a design requirement, such as substances, recyclability or recycled content | Art. 15(1), 18(1) | no. 2 | €10,000 |
| No conformity assessment or technical documentation | Art. 15(2) | no. 3 | €10,000 |
| Documentation or EU declaration of conformity not kept for the required period | Art. 15(3) | no. 4 | €10,000 |
| Empty space ratio above 50% | Art. 24(1) | no. 17 | €10,000 |
| Reuse targets for transport, sales and grouped packaging missed | Art. 29(1), (5), (6) | nos. 23, 25, 26 | €200,000 |
| An online platform not collecting your registration details | Art. 45(4)(b) | no. 33 | €100,000 |
| A fulfilment provider not asking you to correct wrong details | Art. 45(8) | no. 35 | €100,000 |
| Ignoring an enforceable order of a market surveillance authority | Art. 58, 60, 62 | no. 37 | €100,000 |
The PPWR conformity duties are a separate job from LUCID and licensing: see the PPWR in Germany.
VerpackDG § 66 
Regulation (EU) 2025/40 (PPW
Negligence halves the ceiling, and profit can lift it
§ 66(3) sets one maximum per offence, the same for intent and negligence. The general rules of the Administrative Offences Act (OWiG) then adjust it:
- Negligence: half the maximum. § 17(2) OWiG: where a law threatens the same maximum for intentional and negligent acts, negligence can be fined at most half of it.
- The amount within the range depends on how serious the offence is, how much you are to blame and, except for minor offences, your economic situation (§ 17(3) OWiG).
- The gain counts. § 17(4) OWiG: the fine should exceed the economic benefit you drew from the offence, and the statutory maximum may be exceeded to achieve that. Licence fees saved by selling unlicensed are such a benefit.
| Tier in § 66(3) | Intentional, up to | Negligent, up to |
|---|---|---|
| Top tier (e.g. no dual-system licence) | €200,000 | €100,000 |
| Middle tier (e.g. not registered, selling while unregistered) | €100,000 | €50,000 |
| Other offences (e.g. a data report missed) | €10,000 | €5,000 |
These are ceilings, not tariffs. The law sets no fixed amount per case.
Who fines you, and how a case starts
ZSVR does not issue fines. § 66(4) VerpackDG names the authority competent under the law of each federal state (Land). ZSVR's part is to check and pass on what it finds:
- It publishes the list of registered producers online (§ 54(1) no. 1), so a competitor, a marketplace or an authority can see whether a brand is registered.
- It checks data reports and declarations of completeness against the register and against what the dual systems report, and tells the state authorities about irregularities it cannot clear up (§ 54(1) nos. 5 and 7).
- It can revoke a registration (§ 54(1) no. 1).
On top of the fine, § 67 VerpackDG allows the objects the offence relates to, such as the packaged goods, to be confiscated.
VerpackDG § 66 VerpackDG § 54 VerpackDG § 67
Consequences beyond the fine
For most sellers the fine is not the first thing that hurts. The sales bans in § 13 VerpackDG and the checks in Article 45 PPWR act faster:
- You may not sell. § 13(1): a producer that is not properly registered may not make packaging available in Germany, and may not make household packaging available without a dual-system licence.
- Your buyers may not resell. § 13(3): distributors may not make your packaging available if you are not registered or not licensed.
- Your warehouse may not ship. § 13(4): fulfilment service providers may not handle goods of a producer that is not properly registered. Article 45(8) PPWR obliges them to suspend the service until you fix your details.
- Your marketplace checks you. Article 45(4) to (6) PPWR: platforms must collect your registration number and a self-certification, and assess them, before they let you sell. See what each marketplace asks for.
VerpackDG § 13 Regulation (EU) 2025/40 (PPW
How to stop the exposure
Each offence in § 66(1) also covers acting nicht rechtzeitig, too late. Fixing it now does not undo the past, but it ends the breach and cuts off the gain that § 17(4) OWiG would add to a fine.
- Register in LUCID (§ 6(1)). If your company has no establishment in Germany, name your authorised representative in the same registration (§ 5(5)).
- Licence your household packaging with a dual system before the next sale (§ 7(1)). Your representative concludes it in its own name.
- File the data report for what you licensed (§ 9).
- Registered before 12 August 2026? You count as registered under the new law, but changes, such as naming your representative, had to be made by 12 November 2026 (§ 68(2)).
Every deadline and ceiling, each with its paragraph: deadlines and fines dataset.
VerpackDG § 5 VerpackDG § 6 VerpackDG § 7 VerpackDG § 9 VerpackDG § 68
More on Costs
- When am I charged, and is the first year pro rata?
- Is LUCID registration free? What does German packaging compliance actually cost?
- Can I get the licence fee back for damaged or unsold goods?
- Do recyclable packaging and recycled content lower my dual-system fees?
- What is the insolvency-proof guarantee for electronics in Germany, and do I need one?
- Can I show the WEEE disposal cost as a separate line on my customer's invoice in Germany?