As of August 12, 2026, new regulatory framework for packaging will take effect in Germany. The European Packaging Regulation (PPWR) and the national Packaging Act (VerpackDG\/in Germany) will replace the previous Packaging Act. The familiar basic obligations\u2014such as registration, participation in a recycling system, and data reporting\u2014will remain in place. The main change is the question of which company is responsible for which obligations.<\/p>\n
The PPWR Distinguishes Between \u201cProducers\u201d and \u201cManufacturers\u201d<\/strong><\/p>\n Going forward, the PPWR distinguishes between producers and manufacturers. The producer is responsible for ensuring that the packaging complies with the PPWR\u2019s requirements and must demonstrate this through technical documentation and a declaration of conformity, among other things.<\/p>\n The manufacturer, on the other hand, bears extended producer responsibility (EPR) in the EU member state where the packaging becomes waste. This includes, in particular, financing packaging recycling as well as the associated registration and reporting obligations.<\/p>\n In many cases, these two roles overlap. However, in cross-border supply chains, the producer and the manufacturer may be different companies.<\/p>\n How are \u201cproducers\u201d and \u201cmanufacturers\u201d defined?<\/strong><\/p>\n The brand principle plays a key role in this classification: If packaging or packaged products are developed or manufactured under the company\u2019s own name or brand, the company in question is considered both the producer and the manufacturer.<\/p>\n If neither the brand name nor the name of the commissioning company appears on the packaging, the producer is initially identified on the basis of the type of packaging: in the case of transport, service and primary production packaging, obligations may arise even when the packaging is empty. In the case of sales and outer packaging, obligations generally only arise once the packaging has been filled.<\/p>\n The manufacturer is then identified on the basis of the EU Member State in which the packaging becomes waste. In principle, the first company in the domestic supply chain is decisive in this regard. If, however, a delivery is made from abroad directly to an end user in Germany, the foreign company itself is regarded as the manufacturer.<\/p>\n New obligation to appoint an authorised representative for foreign companies<\/strong><\/p>\n A significant change affects companies based outside Germany which, without a German branch, distribute empty packaging or packaged products directly to end users in Germany.<\/p>\n Since 12 August 2026, foreign companies have been required to appoint an authorised representative in Germany. This representative assumes the obligations arising from extended producer responsibility in Germany. There is one exception regarding registration in the LUCID packaging register: this remains the manufacturer\u2019s personal responsibility and cannot be transferred to the authorised representative.<\/p>\n The authorised representative must be specified at the time of initial registration in LUCID. Foreign manufacturers who are already registered will be notified of the missing authorisation after logging in.<\/p>\n New authorisation requirement for certain types of packaging from the end of 2027<\/strong><\/p>\n For packaging not subject to the packaging system, the existing obligations regarding take-back, reuse and recycling remain in place. A new requirement is an additional authorisation procedure with the Central Packaging Register (ZSVR) from the end of 2027.<\/p>\n Manufacturers may fulfil these obligations themselves or transfer them, in whole or in part, to producer responsibility organisations In both cases, the relevant authorisation is required.<\/p>\n The Packaging Act (VerpackDG) provides for transitional arrangements in this regard: manufacturers may continue to operate without authorisation until 31 December 2027, and producer responsibility organisations until 31 October 2027. Authorisation is subject to a fee and is to be granted via an electronic procedure administered by the ZSVR.<\/p>\n