German packaging EPR: frequently asked questions

A company with no establishment in Germany that makes packaging or packaged products available to end users in Germany. PPWR Article 45(3) creates the duty and VerpackDG § 5(2) implements it. ZSVR states plainly that no exemption from this duty is possible. A warehouse or a fulfilment provider is not an establishment; a registered branch or German company is.

12 August 2026, when Regulation (EU) 2025/40 began to apply directly in all 27 member states. If you were already registered in LUCID under the old VerpackG, VerpackDG § 68(2) gives you until 12 November 2026 to file the change naming your representative.

Yes, and it is the most common reason the answer is no. Under domestic precedence the producer is whoever first makes the packaging available in Germany. If your German customer buys and resells, that customer is the producer for those goods. If your customer uses the goods themselves, they are an end user and you are the producer.

No, and they cannot be substituted for each other. Registration in LUCID stays with you: VerpackDG § 5(2) explicitly carves out § 6 registration from what a representative may take on. Everything else under the Act moves to the representative.

€149 a year, with no setup fee, for the packaging mandate. Dual-system licence fees are separate, depend on your materials and weights, and are passed through at the scheme's own rate with no markup. For pure B2B transport packaging there may be no licence fee at all.

No. § 5(2) VerpackDG sets no tonnage, turnover or company-size threshold. One parcel of packaged goods to a German end user is enough. A separate 10-tonne threshold exists in § 9(2), but it only changes how often you report volumes — it does not remove the duty to register, join a system or appoint a representative.

No. The marketplace has its own duty to check you, not to carry your obligation. § 13(4) VerpackDG bars fulfilment service providers from handling goods for producers who are not properly registered, and ZSVR provides an automated register match for that check. In practice a marketplace that cannot verify you deactivates the listing.

No. The test in § 5(2) is Niederlassung — establishment. A VAT registration is a tax status, not an establishment, and a warehouse run by a third party is not yours. A German subsidiary is an establishment, and then that entity carries the obligations directly.

No, and no provider can. § 5(2) mandates the representative for your obligations ‚mit Ausnahme der Registrierung nach § 6‘. Registration is personal to the producer. A representative who offers to register for you is describing something the statute does not permit — though it can prepare everything you paste into LUCID.

Not as one appointment. Article 45(3) PPWR requires a representative in each member state where you first make packaging available and are not established. One company can act for you in several countries, but each appointment is a separate mandate under that country’s law — and the German one must be written in German.

Yes. § 5(2) VerpackDG sets no tonnage, turnover or company-size threshold, and neither does Article 45(3) PPWR. The duty attaches to your status as a producer without a German establishment, not to your volume.

12 November 2026. § 68 VerpackDG gives producers already registered before the new law a transition period to have a Bevollmächtigter named. Producers registering for the first time need the appointment before their first Bereitstellung.

Three things, and the fine is the slowest of them. § 13(1) VerpackDG bars you from making packaging available while you are not properly registered; § 13(4) bars your fulfilment provider from handling your goods, checked against ZSVR's automated register match; and § 66(3) sets fines up to €200,000 depending on the breach.

No. COM(2025) 982 has been on the table since December 2025, Council negotiations on it were discontinued, and the obligation it would suspend has applied since 12 August 2026. Waiting means operating in breach of § 13(1) VerpackDG in the meantime.

No. Enforcement is national: § 66(4) VerpackDG makes the competent authority the one designated under each Land’s law. And the two provisions that bite hardest — § 13(1) and § 13(4) — need no enforcement decision at all. A fulfilment provider that stops handling your goods is not sanctioning you.

Two things, presented in Brussels on 7 September 2026: exempting traders who place under ten tonnes of packaging per year from the representative duty, and suspending registration in the new system until mid-2028, pending a central EU producer register. Both are proposals, not law.

We update this page in the week it is published, including where it ends your need for us, and the change is recorded so you can see what moved and when. We would rather lose the contract than keep a customer who no longer has the obligation — ask us and we will tell you straight whether the duty still applies to you.

The Erzeuger (manufacturer) answers for the packaging’s conformity — its design and composition. The Hersteller (producer) answers for extended producer responsibility, the cost of disposal, in the member state where the packaging becomes waste. ZSVR assesses them in that order, and in cross-border supply chains they often fall to different companies.

ZSVR attributes it to the client, not the provider: where a fulfilment provider packs a client’s goods into shipping packaging that is subject to system participation, the client — the distributor of the goods — must meet the packaging obligations for it.

This is not settled. ZSVR published guidance on the point in August 2026; the European Commission’s FAQ approaches it differently, treating the manufacturer as determined at the empty-packaging stage. We are not going to state a conclusion the sources do not support. The producer question — step 2 — is unaffected and is the one that triggers registration.

It changes the route, not the duty. A German business that uses the goods itself is an end user, so you are still the producer. But B2B transport packaging does not go to a duales System — it is taken back under § 39 or handled by a sonstige Organisation für Herstellerverantwortung approved under § 22.

A registered branch or a German company. A warehouse, a fulfilment centre or a logistics provider is not an establishment, which is why Amazon FBA sellers storing stock in Germany are still caught by the duty.

If those businesses resell your goods, they become the producer and you generally do not. If they use the goods themselves they are end users, and you do. The packaging type then changes what you pay, not whether you need the mandate.

No. Holding a registration does not satisfy VerpackDG § 5(2). Existing registrants must file the change naming a representative by 12 November 2026 under § 68(2).

No. VerpackDG § 5(4) allows exactly one representative per producer, and the appointment must be made by written power of attorney in German. Changing representative means ending the existing mandate first.

No. § 5(2) VerpackDG turns on whether *you* have an establishment in Germany. Stock held in a warehouse operated by someone else — including Amazon FBA — is not your establishment. A German subsidiary is, and then that entity carries the obligations directly.

No. A VAT registration is a tax status, not an establishment. The IT-Recht Kanzlei puts the same point about the PPWR establishment test: „Eine bloße Mehrwertsteuerregistrierung im Zielland genügt dafür nicht.“

It depends on what they do with the goods. If they resell them unchanged, they open the German supply chain and they are the producer. If they use the goods themselves, they are an end user and you are the producer — but B2B transport packaging then goes down the § 39 take-back route, not to a duales System.

Nobody holds that title, because no authority awards it. ZSVR maintains the register and confirms appointments; it does not accredit or rank Bevollmächtigte. Any page claiming a ranking is either a provider ranking itself or an affiliate page. Use the § 5 test to disqualify offers, then compare published prices.

Ask for the German registered entity and its Handelsregister number in writing. § 5(2) VerpackDG requires a Sitz oder Niederlassung in Germany, and ZSVR says the same. Then ask to see the German-language Vollmacht before you pay — § 5(4) requires it to be written and in German.

Only if the scope matches. The two most common gaps are B2B transport packaging, which several providers exclude from the base fee, and the dual-system participation fee, which is a separate unavoidable cost that some providers resell with a margin. Compare year-one totals and scope together.

Yes. The registration is yours and stays yours — that is precisely why § 5(2) carves it out of the mandate. Switching means ending the old appointment, which § 5(6) requires you to notify to ZSVR, and naming the new one. The old representative stays responsible for obligations that arose while it was named.

The same test applies, with one addition: § 13(4) VerpackDG bars fulfilment providers from handling goods for producers who are not properly registered, and ZSVR runs an automated register match. So what matters for a marketplace seller is how fast a provider gets you named in LUCID and confirmed, not which logos are on its site.

Published annual fees run from €149 to €299 for packaging representation, and one provider adds a one-off €89 onboarding fee. Four of the nine providers we could find publish no price at all. Every one of those figures is the representation fee only — the dual-system licence fee is billed separately by all of them.

No, and not with any provider in the table. The licence fee (Lizenzentgelt) is paid per kilogram of packaging to a § 20 dual system, because that money funds collection and recycling rather than the representative's work. We pass it through at the scheme's own rate with no markup; rep-germany.de publishes its own worked example of €35 a year plus per kilogram.

Transport packaging delivered to businesses is generally not system-participation packaging, so no dual system licences it. Instead VerpackDG § 39 puts a take-back duty on the producer, with annual documentation due by 15 May. It is the line where providers diverge most: ecosistant excludes it from its base fee, and the other public pages do not address it either way.

Yes. It is published under CC BY 4.0. Credit “EPR Germany Rep, German EPR provider prices” and link to the page; if you quote a specific provider's figure, link that provider's page too. A JSON version sits at /data/provider-prices.json and a Markdown version at /data/provider-prices.md.

Yes. Everything on these pages is published under CC BY 4.0 — reuse it commercially or otherwise, with attribution to eprgermanyrep.com. Each dataset also has a Markdown and a JSON twin for machine use.

You should not simply trust it, which is why every competing row links to that provider's own published page. Check the numbers at their origin. We include our own price in the same table under the same headings.

Two routes. Household and e-commerce packaging goes to a duales System, approved by the competent Land authority under VerpackDG § 20, which must have nationwide collection, agreements with the municipal waste bodies and its own sorting and recycling capacity. B2B packaging is either taken back by the producer under § 39 or handed to a sonstige Organisation für Herstellerverantwortung approved by ZSVR under § 22.

No. VerpackDG § 7(1) requires participation in one or more systems im Bundesgebiet — the federal territory. The per-Land approval in § 20 is the system's burden: to sell nationwide participation it must hold all sixteen. You sign once.

Because they are quoting different layers. Some quote only the representation fee, some bundle dual-system licensing, some exclude B2B, and some publish an entry price with a separate setup fee. Ask each provider to state the year-one total, whether the dual-system fee is passed through at cost, and whether B2B is in scope.

No. ZSVR states that registration in the LUCID packaging register is free and done online, and the same applies to the data reports. It is also the one duty a representative cannot take over, because § 5(2) VerpackDG carves out § 6.

The system's own rate does not change. What changes is whether your representative passes it through at that rate or adds a margin. Ask for the answer in writing, because a percentage on top compounds with your tonnage and never shows up in an entry price.

In practice yes, because dual systems commonly set a minimum fee, so very small volumes pay the floor rather than the calculated per-kilogram amount. The floor differs by system. Registration itself adds nothing.

It reduces work, not the licence fee. § 9(2) VerpackDG lets producers under 10 tonnes in the previous calendar year replace the ongoing reports under § 9(1) with a single submission by 1 June. Your dual-system participation is still charged on what you actually place on the market.

Acting as your authorised representative under PPWR Article 45(3) and VerpackDG § 5: being named in LUCID, the written German mandate, the dual-system participation contract concluded in our name, annual volume reporting, the Vollständigkeitserklärung where your volumes require one, § 39 scope and documentation, and correspondence with ZSVR.

Because they are not ours to keep. The per-kilogram rate is the licence fee of the dual system that actually collects and recycles your packaging, and it varies with your materials and weights. We pass it through at the scheme's own rate. A provider who bundles it is either capping your volumes or taking a margin on it.

Usually not. Transport packaging delivered to businesses is generally not system-participation packaging, so no dual system is funded to collect it. Instead VerpackDG § 39 puts a take-back duty on the producer, and with non-consumer customers the place of return and the cost allocation can be agreed contractually.

Batteries and business-only electricals, yes — €249 and €349 a year, quoted under Custom. Electricals usable in private households, no: ElektroG § 7(1) requires the representative to lodge an insolvency-proof financial guarantee with the authority every calendar year, and we do not offer what we cannot yet deliver.

No setup fee. The price is €149 per year for the packaging mandate.

Of the published prices we could find, ours at €149 a year with no setup fee is the lowest — and we publish our own price in the same table as everyone else's so you can check that rather than take it from us. Four of the nine other providers publish no price at all.

No, and nobody can. § 5(2) VerpackDG mandates the representative for your obligations ‚mit Ausnahme der Registrierung nach § 6‘. Registration is a höchstpersönliche Pflicht. ZSVR confirms it is free and done online, so there is nothing to buy there.

Yes. § 5(4) VerpackDG requires „eine schriftliche Vollmacht in deutscher Sprache“. If a bilingual version exists, the German text binds. An English-only contract does not satisfy the paragraph.

No. § 5(4): „Jeder Hersteller darf nur einen Bevollmächtigten … beauftragen.“ Not one per stream and not one per marketplace. To switch, you end the first appointment — § 5(6) makes that a notification to ZSVR that takes effect on confirmation — and name the new one.

When ZSVR confirms it. § 5(5) requires you to name the representative as part of your § 6 registration, and the naming „bedarf der Bestätigung durch die Zentrale Stelle Verpackungsregister“. Until then you are not covered.

§ 9 reports are excluded from delegation to an ordinary service provider by § 5(1) sentence 2. § 5(2) excludes only § 6 from the representative's mandate, and § 5(3) says the representative acts as the producer in its own name — so on our reading the reports move with the mandate. That is a reading of how two paragraphs fit, not a sentence in the statute.

No. The marketplace has a duty to check you, not to carry your obligation. § 13(4) VerpackDG bars fulfilment service providers from acting for producers who are not properly registered, and points at Article 30(1)(d) of the Digital Services Act and Article 45(4) PPWR. ZSVR supplies an automated register match, so the check is mechanical.

ZSVR attributes it to the client: where a fulfilment provider packs a client's goods into shipping packaging subject to system participation, the client — the distributor of the goods — must meet the packaging obligations for it.

That is the realistic failure mode, and it does not wait for an authority. A marketplace that cannot verify your registration through the register match has its own exposure under § 13(4) and the DSA, and deactivating the listing is how it removes that exposure.