VerpackG and VerpackDG: German packaging law for sellers abroad

VerpackG, VerpackDG and the PPWR in one paragraph

The Verpackungsgesetz (VerpackG) governed packaging in Germany from 2019. On 12 August 2026 the EU's Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) started to apply in all member states, and Germany replaced the VerpackG with the Verpackungsrecht-Durchführungsgesetz (VerpackDG), published in the Federal Law Gazette in July 2026. The LUCID register, the authority that runs it (the ZSVR) and the dual systems all remain.

Who the law applies to

The duties sit with the producer: in simple terms, the first company that makes packaged goods available on the German market. For cross-border online sales, the ZSVR explains that a company abroad is the producer when it ships directly to an end user in Germany, private or commercial.

• Your brand on the packaging usually makes you its producer, even if someone else made it.
• Shipping packaging counts: boxes, mailers, filler, tape and labels.
• There is no minimum quantity. The duties start with the first parcel.

The four core duties

1. Appoint an authorised representative first if you are based abroad without a German establishment and sell directly to end users in Germany (§ 5 VerpackDG). The LUCID registration form asks you to select them. See authorised representative.
2. Register in LUCID before you place packaging on the German market (§ 6 VerpackDG). Registration is free, and it stays your personal duty even if someone helps you with it.
3. Join a dual system for packaging that ends up with consumers, which for online sellers includes shipping packaging (§ 7 VerpackDG). This is the part that costs money. See the dual system explained.
4. Report your quantities to the dual system, and the same figures in LUCID.

What happens if you skip it

• Sales ban. Packaging from producers that aren't properly registered, or haven't joined a system, may not be placed on the German market (§ 13 VerpackDG). Distributors may not sell it either.
• Marketplaces and fulfilment providers check. Online platforms must collect your registration details, and fulfilment providers may not handle goods of unregistered producers. The ZSVR gives them an automated check against the register.
• Fines. § 66 VerpackDG provides for fines of up to €100,000 for failing to register and up to €200,000 for not joining a system.

What actually changed for small online sellers

• The representative became mandatory for producers abroad who sell directly to end users in Germany. Before 12 August 2026 it was voluntary.
• The producer definition now follows the PPWR, including the brand principle and the country where the packaging becomes waste.
• The basics did not change: register, license, report. Existing LUCID registrations continue, but foreign producers are asked to add their representative.

For sellers based in another EU country, the EU is discussing a suspension of the representative rule for small quantities. As of the date above it is a proposal, not law.

Other German rules you may meet

• Deposit (Pfand) on single-use drink bottles and cans has its own rules and registration.
• Electronics and batteries have separate EPR registrations that LUCID doesn't cover.
• PPWR design rules (labelling, recyclability, substances) apply EU-wide on their own timelines.

Pilot. We're launching, and we are going through our own shop's packaging registration right now. One country costs €249 one-time + €19 / month; the first 20 clients keep these prices for 12 months. Scheme fees are paid separately. Ask us to check your case.