The German Packaging Act (VerpackG) sets strict regulations for businesses placing packaged goods on the German market, enforcing environmental standards for recycling and waste reduction. In effect since January 1, 2019, VerpackG establishes Extended Producer Responsibility (EPR), requiring companies to register their packaging, participate in recycling schemes, and meet specific recycling targets. The law is undergoing major amendments in 2025, strengthening sustainability efforts and placing new obligations on businesses.
This guide provides a comprehensive overview of who is impacted, key requirements, compliance deadlines, reporting obligations, and penalties for non-compliance—helping businesses navigate the evolving regulatory landscape.
Who is Impacted by VerpackG?
Since January 1, 2019, all companies placing packaging on the German market must comply with VerpackG regulations, including:
- Manufacturers producing packaged goods
- Importers bringing packaged products into Germany
- Distributors & Retailers, including e-commerce businesses selling to German customers
VerpackG applies to commercial and industrial packaging and covers plastics, paper/cardboard, glass, metals, composites, wood, and other non-specified packaging materials.
What Are Businesses Required to Do?
Under the German Packaging Pack (VerpackG), businesses placing packaging on the German market must comply with three key obligations to avoid non-compliance.
1. Register with LUCID
Before selling packaged products in Germany, companies must register with the LUCID Packaging Register, managed by the Zentrale Stelle Verpackungsregister (ZSVR). Registration applies to all businesses, even those without a legal entity in Germany. Third-party representation is not required, meaning companies must handle compliance directly.
2. Join an EPR Scheme
Businesses must enroll in a dual system, such as Interzero or Der Grüne Punkt (Green Dot), which manage the collection, sorting, and recycling of packaging waste.
Note: Businesses must pay a licensing fee to participate in a dual system. Fees are determined based on the type and quantity of packaging materials placed on the market. VerpackG requires modulated fees, meaning that environmentally friendly packaging—such as those incorporating recycled materials or being easily recyclable—may incur lower fees, while less sustainable packaging may result in higher costs.
3. Report Packaging Data
Companies must regularly report packaging volumes to both LUCID and their chosen EPR organization. If exact weights aren’t available, businesses may estimate using:
- Product and packaging specifications
- Average weights from suppliers
- Industry benchmarks or EPR-approved calculation tools
Risks of Non-Compliance
Businesses must register with LUCID before selling any packaged goods in Germany. After registration, ongoing reporting is required. Failing to comply can lead to severe penalties, including:
- Fines up to €200,000 per violation
- Bans on selling products in Germany
- Legal actions from competitors through civil enforcement
2025 Amendments to VerpackG
Significant amendments to VerpackG are being implemented in 2025, reflecting Germany’s commitment to sustainability and alignment with broader EU environmental objectives. Businesses involved in the production, import, or distribution of packaging in Germany must comply with these new requirements to maintain market access and avoid penalties.
1. Minimum Recycled Content in Single-Use Plastic Beverage Bottles
- Effective January 1, 2025, single-use plastic beverage bottles made from polyethylene terephthalate (PET) must contain at least 25% recycled material by mass.
- By January 1, 2030, this requirement will expand to all single-use plastic beverage bottles, regardless of material, with a minimum recycled content of 30% by mass.
2. Implementation of the EU Packaging and Packaging Waste Regulation (PPWR)
The European Union’s new Packaging and Packaging Waste Regulation (PPWR) was published on January 22, 2025, and will enter into force on February 11, 2025. While the regulation applies directly across all EU member states, including Germany, its provisions will become applicable starting August 12, 2026.
The PPWR introduces several key measures, including:
- Recyclability Requirements: All packaging must be designed for recyclability, with specific criteria to be defined by the European Commission by January 1, 2028.
- Recycled Content Targets: The regulation sets minimum recycled content requirements, ensuring greater use of recycled materials in packaging.
- Waste Reduction Goals: The EU is implementing binding targets to reduce packaging waste, minimize unnecessary packaging, and promote reusable packaging solutions.
By proactively ensuring compliance, businesses can avoid penalties, maintain market access, and contribute to a more sustainable packaging system in Germany.
Looking Ahead
Germany is continuously updating its packaging laws to align with EU sustainability goals. Anticipated changes may include stricter reporting requirements and expanded obligations for online marketplaces and international sellers. To stay compliant, companies should regularly consult updates from the Central Agency Packaging Register (ZSVR) and their Extended Producer Responsibility (EPR) providers.
Need Help with German Packaging Compliance?
Navigating these evolving regulations can be complex. At Tetra Tech, we have years of product compliance expertise across Europe, offering tailored solutions to help your business meet its compliance obligations effectively. Contact our team of experts at [email protected] to ensure your operations remain compliant and sustainable.
This is the first installment in our blog series on packaging regulations across key EU member states. For detailed insights into other countries’ requirements, explore the articles linked below.
Part 1 (Germany): German Packaging Act (VerpackG): A 2025 Guide to International Packaging Laws (Part 1)
Part 2 (France): France Packaging Regulations: A 2025 Guide to International Packaging Laws (Part 2)
Part 3 (Italy): Italy’s Packaging Regulations: A 2025 Guide to International Packaging Laws (Part 3)
Part 4 (Ireland): Ireland’s Packaging Regulations: A 2025 Guide to International Packaging Laws (Part 4)
Part 5 (The Netherlands): The Netherlands Packaging Management Decree: A 2025 Guide to International Packaging Laws (Part 5)
Part 6 (Belgium): Belgian Packaging Regulations: A 2025 Guide to International Packaging Laws (Part 6)
