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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B2B and transport packaging in Germany

Packaging that never reaches private households is not licensed with a dual system. What applies instead: take-back, other organisations for producer responsibility approved by ZSVR (§ 22 VerpackDG), and the yearly record.

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 businesses is not licensed with a dual system. Instead the producer takes it back or has it recovered, and keeps a record each year. Collection can be handed to an other organisation for producer responsibility approved by ZSVR under § 22 VerpackDG. This page explains the route; collection itself is a separate contract at that organisation's price.

Household or business?

Where the packaging ends upRoute
Private households, or comparable places such as hotels, offices and canteensDual system licence
Only businesses: pallets, stretch film, transport cartons to a resellerTake-back, or an organisation approved under § 22

VerpackDG § 20 VerpackDG § 39

The § 22 organisations

ZSVR approves other organisations for producer responsibility, within three months of a complete application, and publishes the list. Known take-back systems for industrial and commercial packaging include RIGK, GVÖ, KBS and their joint company PACKLIANCE. See the approved bodies dataset.

VerpackDG § 22 RIGK PACKLIANCE (RIGK · GVÖ · KBS

What we do and do not do

We tell you which of your packaging falls under the dual system and which does not. The take-back, the agreement with your customers and the yearly record stay with you; collection, where needed, is a separate contract with a take-back system at its own price.

VerpackDG § 39

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

Is B2B packaging part of the €149?
We tell you which packaging falls outside the dual system. Collection itself is a separate contract with a take-back system.

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.