Selling in Germany? Your Packaging Law Changed on 12 August 2026.

What happened on 12 August 2026?

The German Packaging Act was replaced. Since that date, packaging in Germany is governed by the EU Packaging and Packaging Waste Regulation — Regulation (EU) 2025/40, usually shortened to PPWR — together with a German implementing statute, the Verpackungsrecht-Durchführungsgesetz (VerpackDG). The old Verpackungsgesetz (VerpackG) no longer applies.

The registry authority puts it plainly: the basic obligations — registration, system participation and data reporting — "will remain in place. What will change, however, are the rules governing who is required to fulfil these obligations and under what conditions."

So is this a small change or a big one?

Small for the German importer, large for the foreign brand owner. If you were already registered in Germany, you are still registered and still reporting. Nothing about the machinery changed.

What changed is that the law now names two different roles where the old act had one, and it puts a foreign exporter squarely into the second of them. That is the part worth fifteen minutes of your time.

Does any of this apply to me if I only sell to a German importer?

Yes — but not in the way most exporters assume. You almost certainly do not have to register anything in Germany. Your importer does. That much is unchanged and we will come back to it.

What is new is that the regulation gives the brand owner its own, separate duty: a technical file and a signed declaration that your packaging meets the EU requirements. That duty does not travel to the importer just because the importer is the one who registers.

What is LUCID, and what is a LUCID number?

LUCID is Germany's public packaging register, and the number is your entry in it. It is run by the Zentrale Stelle Verpackungsregister (ZSVR), a foundation with a statutory mandate. Registration is free of charge and entirely online, and the number is issued immediately on completion.

The word "public" is doing real work here. Under section 6 of the VerpackDG the register publishes each producer's registration number and date, name and address, tax reference, packaging types, brand names, and — new since August — their authorised representative. Your buyer can look you up. So can your competitor, and so can your buyer's compliance officer.

Who has to register — me or my German importer?

Whoever is the "producer", and in a normal export sale that is your German importer. The regulation defines a producer as the manufacturer, importer or distributor who "is established in a Member State and makes available for the first time from within the territory of that Member State and on that same territory" the packaged product.

Read it slowly: established in Germany, and making available from within Germany. A company in India shipping a container to a buyer in Hamburg satisfies neither limb. The buyer does, because they are first in the German chain.

Is there any case where I am the producer?

Yes — if you ship straight to the German consumer. The definition has a third limb covering a company "established in a Member State or in a third country" that makes packaging available for the first time in another Member State directly to end users.

That is the e-commerce case: your own webshop delivering to German households, or you selling on a marketplace as the seller of record. No German importer stands between you and the customer, so there is nobody else to be the producer. The registry's own summary of the new rules says it in one line: "A foreign company is only considered the producer if it ships from abroad directly to a (private or commercial) end user."

Do I need an authorised representative in Germany?

Only if you fall into that direct-to-end-user case — and then it is now compulsory. Until 12 August 2026 a foreign company with no German branch could appoint a representative voluntarily. Since that date it is an obligation, and the registry is blunt about the absence of wiggle room: "There is no exemption from this obligation."

The mechanics are worth knowing before you shop for one:

• The representative must be a person or company with a registered office or branch in Germany, and must be independent of you — your own employee cannot be it (name them as a contact person instead)
• The appointment must be a written agreement in German; if there is an English version too, the German one binds
• It needs a handwritten or qualified electronic signature from both sides
• You may appoint one, and their details must be in LUCID before you first supply the German market
• ZSVR does not publish a list of representatives — vetting the provider is your problem

If the importer registers, do I appear anywhere at all?

Your brand does. The register records the brand names under which a producer first makes packaging available in Germany. So your importer's LUCID entry should list your brand — and if it does not, that is a real gap, not a formality, because the register is how a marketplace or a retailer checks whether a given product is covered.

It is worth asking your buyer to confirm your brand is named in their registration. Most disputes we see are not about who registers; they are about a brand that nobody added.

What is "system participation", and who pays for it?

It is the recycling fee, and the producer pays it — again, normally your importer. Registration is free; this is the part that costs money. The producer signs a contract with a "dual system" — a private operator such as Der Grüne Punkt, Interseroh or Reclay — and pays according to the weight and material of the packaging placed on the market.

You can influence what that costs even though you do not pay it. Fees are set by material and mass, so a lighter pack and a simpler material structure are cheaper for your buyer than a heavy multi-layer laminate. When a German buyer pushes back on your pouch specification, this is often why.

What is a "declaration of completeness" and does it reach me?

An audited annual return, due 15 May, and only above real volume. It applies to a producer whose previous-year volumes reached any one of these thresholds:

• Glass — 80 tonnes
• Paper, paperboard and cardboard — 50 tonnes in total
• Ferrous metals, aluminium, plastics, beverage cartons and other composites — 30 tonnes in total

It must be audited by an auditor registered with ZSVR, the deadline cannot be extended, and a late filing is itself an administrative offence. If you are not the producer this is not your filing — but it is the reason your buyer will ask you for exact pack weights by material, and why you should record them while the artwork is being made rather than reconstructing them in May.

If my importer does the registering, what is left for me?

The conformity file — and this is the change that catches exporters out. The new framework separates two roles that the old German act ran together:

• The manufacturer is responsible for the packaging conforming to the EU requirements, and proves it with technical documentation and a declaration of conformity
• The producer carries extended producer responsibility — financing recycling, registering, reporting

Your German importer is the producer. You are very likely the manufacturer, because the regulation says that where a person "has packaging or a packaged product designed or manufactured under its own name or trademark", that person is the manufacturer — whether or not anyone else's trademark also appears on the pack. If your brand is on the pouch, that is you, and it does not matter that the pouch was converted by a third party or that you have never set foot in Germany.

What does the manufacturer actually have to produce?

Three things, before the packaging goes on the market. Article 15 of the regulation requires the manufacturer to:

• Place on the market only packaging that conforms to the requirements in Articles 5 to 12
• Carry out the conformity assessment procedure — or have it carried out on their behalf — and draw up the technical documentation set out in Annex VII
• Draw up an EU declaration of conformity, signed

This is a paperwork duty, not a redesign duty. Most of the substantive design requirements — recyclability performance grades, minimum recycled content, the packaging minimisation rules — bite from 2030, and the harmonised sorting label from 2028. The file is what you need now.

Does the declaration have to be in German?

No. English is expressly allowed, and this is worth knowing. Section 62 of the VerpackDG says a signed version of the EU declaration of conformity must be kept "at the manufacturer's choice, either in German or English."

The caveat is small and manageable: if the competent authority asks, it must be translated into German. So you keep the English original and translate only on demand — you do not need a German-language compliance file sitting on a shelf in Chennai against the day someone asks.

How long do I have to keep it?

Five years for single-use packaging, ten for reusable, counted from the date the packaging was placed on the market — technical documentation and the declaration of conformity alike. For almost everything an Indian food exporter ships, that is the five-year figure.

What if my German buyer sells my product under their own brand?

Then they become the manufacturer, and the conformity file is theirs. The regulation says that where an importer or distributor places packaging on the market "under its own name or trademark", that importer or distributor is treated as the manufacturer and takes on the Article 15 obligations.

This is the private-label case, and it flips the answer cleanly: supply a German retailer's own-brand line and the retailer owns conformity as well as registration. Supply the same factory output under your brand and the file is yours. If you do both, you are the manufacturer for one and not the other — worth getting straight before anyone signs.

What is the consequence of nobody registering?

A ban on selling the goods, which reaches down the chain. Section 13 of the VerpackDG prohibits a producer from making packaging available in Germany if they are not properly registered, and separately prohibits making system-participation packaging available without a system contract.

The subsection that matters to you is the third one: distributors may not make packaging available in Germany if the producer is not properly registered. The registry states the effect in plain terms — failing to register "results in a distribution ban for the products in question that also applies to downstream distributors."

That is why the question is commercial and not merely legal. Your container does not get seized at Hamburg; it gets stuck, because the retailer below your importer cannot lawfully put it on a shelf.

How do I check whether my buyer is registered?

Look them up yourself — the register is public and free. ZSVR publishes the register of producers precisely so that "consumers, distributors and competitors" can search for a producer or a brand name and see whether the registration duty has been met.

One limitation to understand: the register shows registration, not system participation. It will not tell you whether your buyer actually has a contract with a dual system, and the law deliberately leaves proof of that to the parties. System operators issue confirmations to their clients, so the right ask is a copy of that confirmation alongside the LUCID number.

What are the fines, and who issues them?

Up to €200,000, and it is a state authority — not ZSVR — that imposes them. Section 66 of the VerpackDG sets three tiers:

• Up to €200,000 — failing to participate in a system, among other cases
• Up to €100,000 — failing to register, or making packaging available in breach of the distribution ban
• Up to €10,000 — the remaining cases

Enforcement sits with the authority competent under the law of the relevant federal state. ZSVR runs the register and monitors; it is not the body that fines you.

Do I have to print the Green Dot?

No. It is one company's trademark, not a legal marking. This is the most persistent myth in German packaging compliance, and it costs exporters money in both directions — some print it without a licence, others believe printing it makes them compliant.

Der Grüne Punkt is a dual system: one of several competing operators you can contract with. Its own commercial pages separate the two things exactly — you participate in the system to fulfil your legal obligation, and then, "by concluding a trademark license agreement, you can also use the new QR code with our well-known 'Der Grüne Punkt' trademark on your sales packaging."

What about the material codes — PET 1, ALU 41, the triangles?

Optional to apply, but if you apply them they must be the official ones. Section 4 of the VerpackDG says packaging may be marked with the numbers and abbreviations in Annex 2 to identify its material — and then closes the door: using any other numbers or abbreviations for the same materials "is not permitted."

Two drafting rules sit in the annex itself and are easy to miss: abbreviations must be in capitals only, and a composite is marked with a C/ followed by the abbreviation of the main material — which is why a beverage carton is C/PAP 84 and not "carton".

Does Germany have a sorting label like the French Info-tri?

Not a national one — and that is the point of what comes next. France requires the Triman and the Info-tri block on household packaging. Germany has never imposed an equivalent on-pack sorting marking; its system is financial and administrative rather than graphic.

That gap closes from 12 August 2028, when Article 12 of the EU regulation requires packaging to carry a harmonised, pictogram-based label showing its material composition, so that consumers can sort it. It applies EU-wide, with transport packaging and deposit packaging excluded. If you are commissioning artwork meant to last, note the date — but the implementing acts that fix the pictograms are not published yet, so there is nothing to design to today.

What about beverages — the Pfand?

Single-use beverage packaging is generally deposit-bearing, and the initial distributor has to label it. Cans and single-use plastic, glass or PET bottles for water, soft drinks, juices, beer and alcoholic mixed drinks are the standard cases.

The exemptions are narrower than people expect and are set out exhaustively in section 46(4) of the VerpackDG. By volume, packaging under 0.1 litre and over 3.0 litres is out. By format, beverage cartons, polyethylene tubular bags and foil stand-up pouches are out. By content, the list includes wine and wine-based drinks, sparkling wine, spirits taxed under the Alcohol Duty Act, other alcoholic mixed drinks at 15% abv or more, and milk and dairy drinks with at least 50% milk.

Note what stays in: a fruit juice in a PET bottle is deposit-bearing; the same juice in a carton is not. And the film or tray bundling the bottles is ordinary packaging that goes into system participation.

Does the shipping carton and the pallet wrap count?

They are in scope, but they are not the same obligation as your retail pack. The rules distinguish packaging that typically ends up as household waste — your pouch, your jar, the shelf-ready tray — from transport packaging that accumulates at a commercial address.

Household-type packaging is what goes into system participation and is paid for by the kilo. Transport packaging is not system-participation packaging, but it does not disappear from the law: it carries take-back and recovery duties, and LUCID registration covers both categories of packaging, not just the household one. Your buyer registers for both; you just should not assume the shipper carton is invisible.

Is this the same rule I read about for France?

Same skeleton, different flesh — and the two moved within a month of each other. Both countries put the obligation on whoever first places the pack on the national market, which in an ordinary export sale is the local importer. Both made a locally established representative compulsory for foreign sellers this year: France on 10 July 2026, Germany on 12 August 2026.

The differences that matter to your artwork budget:

• France makes you print something — the Triman and Info-tri block. Germany does not, until the EU harmonised label arrives in 2028
• France issues a 15-character unique identifier that must appear in your buyer's terms and on their website. Germany issues a LUCID registration number and publishes it in a public register
• Germany now asks the brand owner for a conformity file. France's scheme has no equivalent demand on the exporter

If France is also on your list, the companion piece is here: Selling in France? The Triman Is Mandatory on Your Pack.

What is coming next, and when?

Three dates worth writing down.

• 31 October 2027 / 31 December 2027 — the transition window for the new ZSVR authorisation procedure covering packaging that is not subject to system participation. Producers may operate without authorisation until the end of 2027, producer responsibility organisations until 31 October 2027. Authorisation will carry a fee
• 12 August 2028 — the harmonised EU sorting label under Article 12, or 24 months after the implementing acts, whichever falls later
• 1 January 2030 — the substantive design requirements, including minimum recycled content in plastic packaging and the packaging minimisation rules

None of these need action this quarter. They matter because packaging artwork and tooling are commissioned once and used for years, and the cheapest time to know about a 2028 label is before you cut the current one.

What should I do this month?

Two emails and one file. Ask your German buyer for their LUCID number, their system participation confirmation, and confirmation that your brand is listed in their registration. Then start the technical documentation and declaration of conformity for your own packs — in English, which the law allows.

If you sell direct to German consumers, the order is different and more urgent: appoint an authorised representative, then register in LUCID yourself, because you cannot complete the registration without naming them.