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 →
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German packaging EPR for B2B suppliers

Packaging that ends up with businesses is outside the dual system but not outside the law. What a supplier to German businesses registers, takes back and documents.

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

Checked: 6 November 2026 — the date every statement on this page was checked against the sources below.

Quick answer

Packaging that ends up only with business end users is not licensed with a dual system and is not reported in LUCID, but you still register in LUCID and take it back. Packaging that reaches private households, or is shipped to consumers, is licensed as usual. Selling to a German reseller usually makes the reseller the producer for those goods.

Start here

VerpackDG § 39 VerpackDG § 22

Electricals for business use

Equipment sold only to businesses still needs registration at stiftung ear, with a take-back concept. See electricals.

ElektroG § 6

Razvan Toma
About the authorRazvan Toma

Razvan Toma is the founder of EPR Germany Rep and of EPR France Rep, the French sister service. He has worked in waste management and recycling since 2009, running waste-separation programmes inside large B2B organisations in France for clients including Chanel, Microsoft, Decathlon, Pirelli, IKEA, Vinci, Capgemini and E.Leclerc. He reads the statutes and the regulator's own guidance directly, and publishes what they say — including when it means telling a visitor they do not need to buy anything.

Razvan on LinkedIn ↗

Frequently asked questions

Do I license packaging that only goes to businesses?
No, it is outside the dual system. You take it back and document it instead.

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.