German packaging EPR glossary

Authorised representative for extended producer responsibility. The company a producer without a German establishment must appoint to carry its obligations under the Act. It must have a Sitz or Niederlassung in Germany, be appointed by written mandate in German, and be named in LUCID. For the obligations it takes on it is the producer in law and acts in its own name. VerpackDG § 5+1

Producer. The economic operator responsible for financing the disposal of packaging in the member state where that packaging becomes waste — the EPR duty. Not necessarily the company that made anything: whoever first opens the supply chain in Germany is the Hersteller there. ZSVR+1

Manufacturer. The operator responsible for the packaging’s conformity — its design and composition. A separate role from Hersteller under the PPWR, determined first. In cross-border supply chains the two often fall to different companies. ZSVR+1

Establishment. The test that decides whether you need a representative at all. A German subsidiary is one. A VAT registration is not, and neither is stock in a warehouse operated by someone else. VerpackDG § 5

The German packaging register, run by ZSVR. Registration is mandatory before you first make packaging available, is free, and is a höchstpersönliche Pflicht — it cannot be delegated to a representative or anyone else. VerpackDG § 6+1

The foundation under public law that runs LUCID, confirms representative appointments, receives the volume reports and publishes the register. It supervises; it does not accredit or rank Bevollmächtigte. ZSVR+1

The German act implementing Regulation (EU) 2025/40. It replaced the Verpackungsgesetz (VerpackG) on 12 August 2026, which is why older sources cite § 35 VerpackG for the representative duty and the current provision is § 5 VerpackDG. VerpackDG § 5+1

The EU Packaging and Packaging Waste Regulation. Directly applicable since 12 August 2026. Article 45(3) is the provision requiring an authorised representative in each member state where a producer first makes packaging available and is not established. Regulation (EU) 2025/40 (PPW+1

A privately operated household collection scheme. Producers of systembeteiligungspflichtige Verpackungen must participate in at least one before making them available. Each is approved by the competent authority of every Land and publishes its own per-kilogram rates. VerpackDG § 7+2

Subject to system participation. Packaging that typically ends up as waste with a private final consumer — the household and e-commerce packaging that must go to a duales System, as distinct from B2B transport packaging. VerpackDG § 7

End user. Whoever receives the goods without reselling them — a consumer, but also a business that uses the goods itself. Selling to a German end user is what makes a foreign company the producer in Germany. Regulation (EU) 2025/40 (PPW+1

Declaration of completeness. An audited annual declaration of the packaging volumes placed on the market, required above statutory thresholds and deposited with ZSVR. VerpackDG § 10

Volume report to ZSVR under § 9. Filed as each system participation is made; producers under 10 tonnes in the previous calendar year instead file once a year by 1 June. VerpackDG § 9

A service provider performing at least two of storing, packing, addressing and dispatching without owning the goods. Barred by § 13(4) from handling goods for producers who are not properly registered. Postal and parcel carriers are expressly not included. VerpackDG § 13+1

The mandate itself. Must be written and in German, must exist before the first Bereitstellung, and is uploaded with your LUCID registration under § 6(2) no. 2. VerpackDG § 5+1