EPR Packaging in Germany (VerpackG): Compliance for E-commerce Sellers

If you place packaged goods on the German market, compliance with the German Packaging Act (VerpackG) is mandatory. Germany enforces one of the strictest Extended Producer Responsibility (EPR) systems in Europe, requiring businesses to finance the collection, sorting, and recycling of packaging waste they introduce into the market.

This guide explains everything you need to know about EPR Packaging compliance in Germany, including registration, reporting obligations, fees, and penalties.

1. Introduction to EPR in Germany

Extended Producer Responsibility (EPR) is an environmental policy that makes producers financially and operationally responsible for the entire lifecycle of their packaging waste, including collection and recycling.

The goal is to promote a circular economy by reducing packaging waste and encouraging sustainable design and material use.

2. Legal Framework and Regulations in Germany

The main legislation governing packaging EPR in Germany is the Packaging Act (Verpackungsgesetz / VerpackG), supervised by the Central Agency Packaging Register (ZSVR).

Recent regulatory updates include:

• Deposit Expansion (2024): €0.25 deposit extended to single-use plastic bottles containing dairy products
• Recycled Content Mandate (2025): PET beverage bottles must contain at least 25% recycled plastic

These changes tie into the upcoming EU PPWR packaging compliance requirements set to take effect across the bloc.

3. Who Must Register for EPR Packaging (VerpackG) in Germany ?

You must comply if you are the first entity placing packaged goods on the German market.

• Domestic manufacturers
• Importers of packaged goods into Germany, often through an Importer of Record (IOR/EOR) service
• Online sellers (Amazon, Shopify, Etsy, dropshipping businesses)

There is no minimum threshold—compliance begins with the first product sold.

4. EPR Categories Packaging (VerpackG)

Packaging is divided into two compliance categories:

• B2C Packaging (System Participation Required): Sales packaging, shipping packaging, service packaging (e.g., cups, bakery bags) that ends up in household waste
• B2B Packaging (No System Fees): Transport packaging used only between businesses, though still subject to LUCID registration and return obligations

5. EPR Registration Process in Germany for Packaging (VerpackG)

1. Register in the LUCID Packaging Register to obtain your EPR registration number—see our step-by-step LUCID registration guide
2. Sign a contract with an approved Dual System (e.g., Der Grüne Punkt, Lizenzero)
3. Report packaging volumes (material type and weight) to both LUCID and your Dual System
4. Ensure data consistency across all reporting systems

You can also read our detailed overview of LUCID registration in Germany for a full walkthrough.

6. Authorized Representative Requirements

Foreign companies without a German branch may appoint an Authorized Representative to manage compliance obligations.

This representative handles registration, reporting, and communication with regulatory authorities and Dual Systems.

7. Reporting Obligations and Deadlines

Companies must comply with strict annual reporting requirements:

• Yearly Forecast: By December 31st, estimated packaging volumes for the upcoming year
• Annual Report: By May 15th, final packaging volumes for the previous year
• Declaration of Completeness: Required for companies exceeding thresholds (glass, plastics, metals, paper/cardboard)

8. EPR Fees and Eco-Contributions

Fees are calculated based on packaging material type and total weight placed on the market.

Germany applies eco-modulation under Section 21 of VerpackG:

• Lower fees for recyclable and sustainable packaging designs
• Higher fees for difficult-to-recycle materials

For a full breakdown of service costs related to compliance registrations, see our pricing page.

9. Labeling Requirements and Compliance

Unlike France, Germany does not require a universal recycling label for standard packaging.

However:

• Deposit packaging must display the official DPG deposit logo (Pfandsystem)
• Future EU Packaging and Packaging Waste Regulation (PPWR) will introduce harmonized labeling requirements

By comparison, France requires the Triman logo on packaging for sorting guidance, so sellers active in both markets should track each country's distinct labeling rules.

10. Penalties for Non-Compliance

• Sales bans and marketplace delisting (Amazon, eBay, etc.)
• Fines up to €100,000 for LUCID registration violations
• Fines up to €200,000 for failure to participate in a Dual System
• Legal enforcement through competitor-issued cease-and-desist actions (Abmahnungen)

Given the complexity of packaging compliance in Germany, many sellers—including those managing EPR for Amazon sellers in Germany—choose to work with a dedicated compliance partner to avoid registration errors and missed deadlines. If you need help identifying the correct Dual System, registering in LUCID, or managing annual declarations, contact our compliance team for tailored support.