Germany's VerpackDG Is in Force: The 12 November 2026 LUCID Update and the 31 December 2026 End of Existing System Participations
What Has Changed in Germany Since Our June Article on the VerpackDG?
Germany's Verpackungsrecht-Durchführungsgesetz, the VerpackDG, has applied since 12 August 2026 and replaces the Verpackungsgesetz, according to the Federal Environment Ministry. The act was signed on 13 July 2026 and published in the Federal Law Gazette as BGBl. 2026 I Nr. 207 on 17 July 2026, and section 68 of the VerpackDG sets its transition dates.
Our June 2026 article on the VerpackDG and LUCID was written between the Bundestag vote and the publication of the law. This article reads the published act on the federal law portal and the pages of the Zentrale Stelle Verpackungsregister on 21 October 2026, for brands, importers, distance sellers and distributors placing packaged goods on the German market. Nothing here is legal advice.
Key Facts
- The Federal Environment Ministry states in its press release of 12 August 2026 that the VerpackDG took effect on 12 August 2026 and replaces the previous Verpackungsgesetz.
- Under section 68(2) of the VerpackDG, manufacturers registering for the first time do so by 12 September 2026, and those registered under the old law make the required changes by 12 November 2026.
- Under section 68(1) of the VerpackDG, system participations concluded before 12 August 2026 continue, unless otherwise agreed, at the latest until 31 December 2026.
- Under Article 44(2) of Regulation (EU) 2025/40, producers register in each Member State where they make packaging or packaged products available for the first time.
- Regulation (EU) 2025/40 applies to all packaging, regardless of material, whether household, commercial or industrial, under Article 2(1).
How Did the VerpackDG Get From Draft to Law?
The VerpackDG went from a cabinet decision on 11 February 2026 to Bundestag adoption on 11 June 2026, signature on 13 July 2026 and publication on 17 July 2026, according to the Federal Environment Ministry and the Federal Law Gazette. The VerpackDG has applied since 12 August 2026, the date from which Regulation (EU) 2025/40 applies.
The VerpackDG is the German act that implements Regulation (EU) 2025/40 at national level and organises the register, the producer responsibility systems and the competent authorities. The Bavarian environmental business portal states that the VerpackDG is Article 1 of the published act, that the former Verpackungsgesetz is no longer in force, and that many provisions match the old law, so that existing procedures continue.
What Do the Transition Dates of Section 68 VerpackDG Ask For?
Section 68 of the VerpackDG sets three 2026 dates: manufacturers obliged to register for the first time register by 12 September 2026, manufacturers registered under the old law make the required changes to their registration data by 12 November 2026, and system participations concluded before 12 August 2026 end on 31 December 2026 at the latest.
| Date | Who | What the VerpackDG asks | Provision |
|---|---|---|---|
| 12 August 2026 | Everyone placing packaging or packaged goods on the German market | Regulation (EU) 2025/40 and the VerpackDG apply; the Verpackungsgesetz is replaced | Article 71 of Regulation (EU) 2025/40 |
| 12 September 2026 | Manufacturers obliged to register for the first time | Register with the Zentrale Stelle Verpackungsregister | Section 68(2) VerpackDG |
| 12 November 2026 | Manufacturers registered under the old law, who count as registered under section 6 | Make the changes to registration data required under section 6(1), second sentence | Section 68(2) VerpackDG |
| 31 December 2026 | Producers with a system participation concluded before 12 August 2026 | The participation continues, unless otherwise agreed, at the latest until this date | Section 68(1) VerpackDG |
| 31 October 2027 | Industry solutions and other producer responsibility organisations already operating | May carry out their tasks without approval until this date | Section 68(6), (7) and (12) VerpackDG |
| 31 December 2027 | Manufacturers of packaging not subject to system participation | May supply that packaging without approval under section 19 until this date | Section 68(9) VerpackDG |
Under section 6(1) of the VerpackDG, manufacturers notify changes to their registration data without delay, including changes to an appointed authorised representative for the extended producer responsibility. Section 6(2) lists the registration data, among them the brand names under which the manufacturer first places its packaging on the market in Germany and the packaging concerned, by category.
Who Is the Producer in Germany Now, and What Does the Brand Principle Change?
Under Article 3(1)(15) of Regulation (EU) 2025/40, a producer is a manufacturer, importer or distributor that makes packaging or packaged products available for the first time in a Member State, including a seller established in another Member State or a third country that supplies end users there directly. The Zentrale Stelle Verpackungsregister applies that definition in LUCID.
A manufacturer is, under Article 3(1)(13), the person that manufactures packaging or a packaged product, or that has it designed or manufactured under its own name or trademark, regardless of whether any other trademark is visible on the packaging; point (b) contains an exception for micro-enterprises supplied within the same Member State. The Zentrale Stelle Verpackungsregister calls the own-name rule brand precedence and treats such a company as manufacturer and producer.
Where no own brand is involved, the authority separates two steps. The manufacturer role depends on the packaging type: transport, service or primary production packaging triggers obligations even when empty, sales and grouped packaging generally once filled, and there is exactly one manufacturer per unit of packaging across the entire EU. The producer role then depends on the Member State where the packaging becomes waste, and a foreign company is the producer only if it ships directly to a private or commercial end user.
For retailers' own brands, the Zentrale Stelle Verpackungsregister reports that the second edition of the European Commission's PPWR FAQs, released on 3 August 2026, lets the commissioning company set the packaging characteristics even where the packaging also bears the manufacturer's name. The authority concludes that the retailer is the manufacturer and usually also the producer that undertakes system participation in Germany; see our article on private label and own brands.
What Do Importers and Distance Sellers Have to Do in LUCID?
A producer without an establishment in Germany commissions one authorised representative for the extended producer responsibility under section 5 of the VerpackDG, by written power of attorney in German, and names that representative to the Zentrale Stelle Verpackungsregister within its LUCID registration, while registration itself stays with the producer.
Under Article 45(3) of Regulation (EU) 2025/40, a producer under Article 3(1)(15)(c) or (d) appoints, by written mandate, an authorised representative for the extended producer responsibility in each Member State where it makes packaging available for the first time, other than its own. Member States may require the same of producers established in third countries.
Under section 5 of the VerpackDG, the representative is commissioned before the first making available in Germany, a producer may commission only one, and section 5(2) leaves registration under section 6 with the producer itself.
A suspension of the Article 45(3) obligation is still under negotiation: on Commission proposal COM(2025) 982, the European Parliament adopted its position on 20 October 2026 and the Council its mandate on 21 October 2026, with different scopes, and no amending regulation had been adopted on 3 November 2026. Until one is published, the obligation applies; see our article on the Parliament vote and the Council mandate and, for the choice of Member State, our article on distance selling.
Under Article 44(4), producers shall not make packaging available for the first time in a Member State where they are not registered. Under section 13 of the VerpackDG, distributors and fulfilment service providers may not handle packaging whose producers are not properly registered. Under Article 45(4), online platforms obtain the producer's registration number in the consumer's Member State before allowing it to use their services.
What Remains of the Verpackungsgesetz Under the VerpackDG?
The VerpackDG keeps the rules of the Verpackungsgesetz as far as possible, according to the Federal Environment Ministry, in particular the established producer responsibility systems. Registration in LUCID, system participation, data reporting and the annual minimum standard for recyclability continue under the VerpackDG, completed by an authorisation requirement for some organisations and producers.
System participation is the obligation to pay for the recycling of packaging subject to system participation through an agreement with a system. The authority's page on the implementation act states that LUCID lets the authority check whether all parties have properly reported their volumes. Because section 68(1) ends old participations on 31 December 2026 at the latest, a producer checks with its system which agreement covers packaging supplied from 1 January 2027.
The minimum standard is published on 1 September of each year, according to the same page. On 31 August 2026 the authority and the German Environment Agency published the 2026 edition of the minimum standard, with the methodology unchanged.
Under section 26a of the VerpackDG, the environment ministry adopts ordinances on the ecological design of participation fees, with incentives for recyclability and recycled content. Section 26a applies the minimum standard until the delegated acts under Article 6(4)(a) to (c) of the Regulation apply; under Article 6(4), the Commission adopts delegated acts establishing design for recycling criteria and recyclability performance grades by 1 January 2028.
The ministry adds that organisations taking on producer responsibility for several producers, and producers of commercial packaging, need an authorisation, which section 68 phases in by 31 October and 31 December 2027.
What Does the VerpackDG Mean for Each Role on the German Market?
Under the VerpackDG, each role checks one point first: brand owners their LUCID entry, importers their producer status, distance sellers their authorised representative, and distributors the registration of each producer they supply, while every producer checks which system participation covers packaging supplied from 1 January 2027.
- Brand owners and retailers with own brands. The company under whose name or brand the packaging is made is manufacturer and producer, and section 6(2) asks for its brand names.
- Importers established in Germany. An importer that makes packaged products available for the first time in Germany is a producer under Article 3(1)(15)(b), and also the manufacturer where the goods carry its own brand.
- Distance sellers outside Germany. A seller shipping directly to German end users is a producer under Article 3(1)(15)(c) or (d), registers in LUCID and names its authorised representative there.
- Distributors, platforms and fulfilment providers. Under Article 19(2)(a), distributors verify before making packaging available that the producer is registered in the Article 44 register, and section 13 of the VerpackDG applies the same bar in Germany.
Under Article 68, Member States lay down their rules on penalties by 12 February 2027; this article does not describe the German rules. For the registers of the other Member States, see our guide to producer registration in every EU market.
What Does the Referential Not Confirm?
Our dated PPWR referential (baseline reviewed 3 October 2026) confirms two statements here: the scope of Article 2(1) and the recyclability obligation of Article 6(1) in the FAQ. The points below are not recorded in it.
- Articles 3(1)(13), 3(1)(15), 6(4), 19(2)(a), 44(2), 44(4), 45(3), 45(4), 68 and 71 of Regulation (EU) 2025/40, read on the Official Journal text, not recorded in our referential.
- The status of COM(2025) 982 is not tracked by our referential; on 3 November 2026, the Parliament position of 20 October 2026 and the Council mandate of 21 October 2026 were public, and no amending regulation had been adopted.
- Every German statement, read on the federal law portal, the Federal Law Gazette, the Federal Environment Ministry, the Bavarian environmental business portal and the Zentrale Stelle Verpackungsregister on 21 October 2026; section 68 of the VerpackDG and the authority's news page were read again on 3 November 2026.
Frequently Asked Questions
Does a LUCID registration made under the Verpackungsgesetz remain valid?
Yes. Under section 68(2) of the VerpackDG, a manufacturer registered under the old law counts as registered under section 6, and the changes required under section 6(1), second sentence, are due by 12 November 2026.
Does the VerpackDG change the PPWR obligations on the packaging itself?
No. Under Article 6(1), all packaging placed on the market shall be recyclable, an obligation that has applied since 12 August 2026, transport packaging included. The VerpackDG organises the register, the systems and the authorities in Germany; the design, substance and labelling rules come from the Regulation.
Is a software provider or a dual system my authorised representative?
Not by default. Under Article 45(3), the producer appoints its authorised representative for the extended producer responsibility by written mandate, and section 5(4) of the VerpackDG requires a written power of attorney in German. PPWR Connect is software and is neither.
How PPWR Connect Helps
Since 12 September 2026, markets in PPWR Connect are jurisdictions: registrations, volumes and the EPR matrix follow the markets a SKU is sold in, and a per-market obligation profile answers who is the producer per jurisdiction. Since 24 August 2026, packaging items can be organised by production site and by brand, and past EPR declaration runs are kept and consultable instead of being overwritten; since 13 September 2026, EPR declarations record what they were computed from, with an input hash and references. Since 15 October 2026, the action center groups actions by packaging, and Mark done records who did it and when. The Academy offers the course "EPR in the EU: PPWR Rules and National Schemes". PPWR Connect is software, not a producer responsibility organisation, a dual system, an authorised representative or a legal adviser, and it does not register a producer in LUCID. Start with our PPWR compliance software or the PPWR readiness assessment.
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Rutherford (rutherford.fr) develops production control software for offset printers and converters, including ColorLoop. Veoria (veoria.com) develops inline colour measurement for label and packaging presses, including DeltaOne.