Checked: 6 November 2026 — the date every statement on this page was checked against the sources below.
The PPWR, Regulation (EU) 2025/40, has applied since 12 August 2026. In Germany it works together with the VerpackDG, which took over from the Packaging Act on the same day. What changed at once: a producer with no establishment in Germany must appoint an authorised representative (Article 45(3), § 5 VerpackDG), and limits on PFAS in food-contact packaging apply. The design rules on labels, recyclability, recycled content and empty space follow from 2028 and 2030 onwards. Sources (2)
Regulation (EU) 2025/40, conRegulation (EU) 2025/40, consolidated text (EUR-Lex)Regulation (EU) 2025/40 (PPWRegulation (EU) 2025/40 (PPWR)
What already applies
| Rule | Since | Where |
|---|---|---|
| The regulation applies | 12 August 2026 | Article 71 |
| Authorised representative for producers not established in the member state | 12 August 2026 | Article 45(3), § 5 VerpackDG |
| PFAS limit values for food-contact packaging | 12 August 2026 | Article 5 |
Regulation (EU) 2025/40, con 
VerpackDG § 5
What comes next
| Rule | From | Where |
|---|---|---|
| Harmonised sorting label on packaging | 12 August 2028, or 24 months after the implementing acts, whichever is later | Article 12 |
| Packaging must be recyclable, grades A, B or C | 1 January 2030, or 24 months after the delegated acts, whichever is later | Article 6 |
| Minimum recycled content in plastic packaging, for example 35% for most non-contact-sensitive plastic packaging | 1 January 2030, or 3 years after the implementing act, whichever is later | Article 7 |
| Maximum empty space ratio of 50% for e-commerce, grouped and transport packaging | 1 January 2030, or 3 years after the implementing acts, whichever is later | Article 24 |
| Packaging must be recyclable, grades A or B | 1 January 2038 | Article 6 |
How the PPWR and the VerpackDG fit together
The PPWR is directly applicable in every member state. The VerpackDG carries out what the regulation leaves to Germany: the LUCID register, the dual systems, the representative and the fines. The full text of § 5 is on our law page.
Regulation (EU) 2025/40 (PPW VerpackDG § 5
What to do now
- Register in LUCID and, without a German establishment, appoint a representative. See authorised representative in Germany.
- Keep your packaging licensed and reported. See packaging EPR.
- Plan packaging changes for 2028 and 2030 with your suppliers: labels, recyclability and, for e-commerce, box sizes.
PPWR Article 45 authorised representative in Germany: who needs one
Article 45(3) of Regulation (EU) 2025/40 requires producers that sell packaged goods directly to end users in a member state where they are not established to appoint an authorised representative there by written mandate. Points (c) and (d) of Article 3(1)(15) cover such producers whether they are established in another member state or in a third country. Germany applies it through § 5(2) VerpackDG, since 12 August 2026.
| Your situation | Representative in Germany? |
|---|---|
| EU company selling directly to consumers in Germany (own shop, Amazon, eBay, Etsy) | Yes, § 5(2) VerpackDG |
| Non-EU company (US, UK, China…) selling directly to consumers in Germany | Yes, on the same terms |
| Company selling only to a German importer or retailer that resells | No for that flow: the German buyer first makes the goods available and is the producer |
| Company with its own establishment in Germany | No: it registers in LUCID itself |
There is no size threshold and no exemption: ZSVR states that an exemption from this duty is not possible.
PPWR Article 17 versus Article 45: two different representatives
| Topic | Article 17 | Article 45(3) |
|---|---|---|
| Who appoints | A manufacturer of packaging, if it chooses to | A producer not established in the member state, compulsory |
| What it covers | Conformity: keeps the EU declaration of conformity and technical documentation for market surveillance (5 years, or 10 for reusable packaging) | Extended producer responsibility: system participation, data reports, declaration of completeness |
| In Germany | Market surveillance rules | § 5 VerpackDG, named in LUCID |
One does not perform the other. Our €149 a year mandate is the Article 45(3) and § 5 VerpackDG role. For conformity documents see the PPWR declaration of conformity.
Article 45(3) in practice: what we do as your representative in Germany
- You sign the written mandate in German, with an English translation alongside, by hand or with a qualified electronic signature.
- You register in LUCID yourself and name us there; our LUCID ID is DE8516653799349. We confirm the appointment the same day.
- We take out the dual-system participation for your household packaging in our own name (§ 5(3) VerpackDG), at the system's own rate.
- We file the data reports to ZSVR from the weights you give us, and the declaration of completeness where your volumes require one.
€149 a year, no setup fee. Your LUCID registration stays in your own name: § 5(2) does not allow registration to be handed over.
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 ↗