Checked: 7 November 2026 — the date every statement on this page was checked against the sources below.
Packaging that only reaches business end users is not licensed with a dual system and not reported to LUCID, but it is not free of duties. The supplier takes it back or has it recovered and documents it each year (§ 39 VerpackDG). From 2028 it also needs a ZSVR approval under § 19, unless an approved organisation under § 22 carries its responsibility. Sources (2)
VerpackDG § 19VerpackDG § 19VerpackDG § 22VerpackDG § 22
Illustrative example. This is not one of our clients: the business is invented, while the law and our published prices are real.
The situation
A machine-parts maker in northern Italy ships parts to German factories on wooden pallets, wrapped in stretch film, with cardboard corner protection. Nothing goes to private households.
What applies
| Duty | Applies? |
|---|---|
| Dual-system licence | No: the packaging never reaches households (B2B packaging) |
| Data report to LUCID | No (details) |
| Take-back, recovery and a yearly record | Yes (what to document) |
| ZSVR approval under § 19 | Yes, from 1 January 2028; until 31 December 2027 the transition applies (§ 19 approval) |
VerpackDG § 39 VerpackDG § 19 VerpackDG § 22 VerpackDG § 68
When a reseller buys
If the buyer is a German distributor that resells the parts, the distributor is usually the producer for that packaging. See selling to a German retailer.
Where we help
We tell you which of your packaging falls under the dual system and which does not. Collection, where needed, is a separate contract with a take-back system at its own price.
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 ↗