Checked: 6 November 2026 — the date every statement on this page was checked against the sources below.
Large volumes add one duty: above the thresholds, an audited declaration of completeness by 15 May. The thresholds are, in the previous calendar year, 80 tonnes of glass, 50 tonnes of paper and cardboard or 30 tonnes of lightweight packaging. Everything else works as for any producer: LUCID registration, the dual-system licence for household packaging, and a representative without a German establishment. Sources (2)
VerpackDG § 10VerpackDG § 10VerpackDG § 39VerpackDG § 39
Start here
- Declaration of completeness: the thresholds
- When to report packaging volumes
- Industrial packaging and large producers
- When volumes differ from what was licensed
B2B packaging
Pallets, big bags and stretch film delivered to businesses fall outside the dual system. See B2B and transport packaging.
Pricing
Our flat fee does not change with volume. For several brands, several companies or electricals and batteries together, ask us for a quote. See pricing.
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 ↗