The Packaging Law Implementation Act, known as the VerpackDG, was published in the Federal Law Gazette on 07/17/2026. Since 08/12/2026, it has provided the German implementation framework for the new European Packaging Regulation (EU) 2025/40. The new law introduces a number of changes that are relevant to a wide range of market participants.
What exactly do you need to consider? We explain the most important changes and highlight what online retailers in particular need to know. This article is continuously updated to reflect the latest developments.
Contents:
Background: The New EU Packaging Regulation (PPWR)
The new European Packaging Regulation (EU) 2025/40, known as the Packaging and Packaging Waste Regulation (PPWR), replaced the previous EU Packaging Directive (94/62/EC) on 08/12/2026. Since then, the updated legal framework has applied equally and bindingly across all 27 EU Member States.
This also affects German legislation. Until now, packaging EPR in Germany was governed by the German Packaging Act, the VerpackG, under the EU Packaging Directive (94/62/EC). It has now been replaced by the new VerpackDG, the Packaging Law Implementation Act, which applies under the new regulation. Read the law here in German.
Comprehensive PPWR guide for online retailers
- Compact explanation: What changes with the EU packaging regulation PPWR
- The 5 biggest challenges for online retailers, with practical examples
- A clear implementation timeline
- Action guide & checklist with deadlines
Changes: What's New with the VerpackDG?
The fundamental obligations that already applied under the previous German Packaging Act, the VerpackG, when placing packaging on the market remain in place. These include the registration obligation, system participation, and quantity reporting.
The following areas are particularly relevant to you and your e-commerce business:
- “Manufacturer” and “producer”: What is the difference?
- Packaging subject to system participation and packaging not subject to system participation
- Authorized representatives for foreign companies
- Important for 2026: Declaration of completeness under the old and new laws
Manufacturer and Producer: What Is the Difference?
The VerpackDG redefines several roles and their respective responsibilities. Depending on the role you have, different obligations may apply to you as an online retailer.
Here, we take a closer look at the two most important roles: manufacturer and producer. Although these terms are sometimes used interchangeably in everyday language, they come with very different obligations.
The manufacturer (German: Erzeuger) under the VerpackDG and therefore under the PPWR is the party responsible for ensuring that the packaging is compliant. Evidence that the packaging meets the requirements of the PPWR must be provided through technical documentation and a Declaration of Conformity.
The producer (German: Hersteller) under the VerpackDG and therefore under the PPWR is the party that bears extended producer responsibility, or EPR, in the EU Member State where the packaging becomes waste. The producer is primarily responsible for financing packaging recycling and for meeting the associated registration and reporting obligations.
Important: In some cases, the same party may hold both roles. In that case, the party is responsible for meeting the obligations associated with both roles.
So, who is the manufacturer and who is the producer?
Manufacturer
A manufacturer within the meaning of Article 3 of the PPWR, which is also referenced by the VerpackDG within its scope of application, is any natural or legal person that manufactures packaging or packaged products itself, or has them designed or manufactured under its own name or trademark.
Important to note: For any given packaging, there is exactly one manufacturer across the EU.
Producer
A producer within the meaning of Article 3 of the PPWR, which is also referenced by the VerpackDG within its scope of application, is a manufacturer, importer, or distributor that makes packaging available for the first time in the EU Member State where that packaging will eventually become waste.
Sounds complicated? In this video, Tibor explains the difference without the legal jargon:
Packaging Subject to System Participation and Packaging Not Subject to System Participation
Under the VerpackDG, packaging subject to system participation includes sales packaging, grouped packaging, primary production packaging, and transport packaging if, after use, it predominantly becomes waste in private households or at comparable sources of waste.
Section 3(7) of the VerpackDG defines what qualifies as a comparable source of waste. Examples include hotels, schools, and craft businesses.
Shipping packaging typically used in e-commerce and service packaging are always subject to system participation.
The following types of packaging are not subject to system participation:
Packaging that is demonstrably not distributed to end recipients in Germany and is instead intended for sale abroad.
Packaging that typically becomes waste in commercial or industrial settings rather than in private households or at comparable sources of waste.
This also includes packaging intended for reuse, meaning reusable packaging, packaging that is part of a deposit system, such as single-use beverage packaging subject to a deposit, and sales packaging containing hazardous substances.
Producers of packaging that is not subject to system participation under the VerpackDG are typically companies that distribute B2B transport cartons, pallet wrap, industrial packaging, or sales packaging. This packaging typically becomes waste at the premises of commercial or industrial customers rather than in private households or at comparable sources of waste.
Important for producers of packaging that is not subject to system participation: By 10/31/2027, producers of this type of packaging in Germany must also be approved by the ZSVR in accordance with Section 19 of the VerpackDG. This applies if the producer has not previously appointed another producer responsibility organization in the ZSVR register.
If neither the producer’s approval nor the appointment of such an organization is in place by 10/31/2027, the relevant packaging that is not subject to system participation may no longer be legally distributed in Germany.
You can find more information about system participation on the ZSVR website.
Authorized Representatives for Foreign Companies
Is your company based outside Germany, does it supply empty packaging or packaged products directly to end recipients, and does it have no establishment in Germany?
If so, as the producer of this packaging, you have been required to appoint an authorized representative since 08/12/2026.
The authorized representative is expected to fully assume the represented company’s obligations under the PPWR and the VerpackDG and fulfill these obligations in its own name in Germany.
The only exception, in accordance with Article 5(2) of the VerpackDG, is registration in the LUCID Packaging Register. You must complete this registration yourself because it is an obligation that may only be fulfilled by the producer. You must also continue to make any changes to your registration details yourself.
Any natural or legal person may take on the role of authorized representative if they:
- have a registered office or establishment in Germany,
• enter into a written contract with you in German covering their appointment as your authorized representative,
• have a separate login as an authorized representative in the LUCID Packaging Register, and
• are not an internal member of your company.
Important: Appointing a company in LUCID alone does not automatically make that company your authorized representative. Make sure the contractual arrangements and official appointment have been agreed in advance so that the selected authorized representative formally accepts the appointment.
ecosistant can act as your authorized representative. Learn more here.
Important for 2026: Declaration of Completeness Under the Old and New Laws
Companies that exceed the legally defined material thresholds, for example more than 50 metric tons of cardboard in the previous year, are required to submit a declaration of completeness to the ZSVR.
For the 2026 reporting year, a single declaration of completeness must be prepared. Quantities must be reported according to the applicable law for each period:
- Quantities from 01/01/2026 through 08/11/2026 must be considered under the previous German Packaging Act, the VerpackG.
• Quantities from 08/12/2026 through 12/31/2026 must be considered under the new VerpackDG.
The audit guidelines applicable since 2024 must also be taken into account. Contact your auditor early. The submission deadline for the 2026 reporting year is 05/15/2027.
The ZSVR provides detailed information on this topic on its official website.
How ecosistant Can Help Your Company
ecosistant offers suitable service solutions for both German and foreign companies.
For companies based in Germany, we can assist in particular with:
- LUCID registration,
- completing the required system participation,
- ongoing quantity reporting, and
- additional compliance with German packaging obligations.
For companies without a registered office in Germany, we can also help meet the requirements relating to an authorized representative.
The PPWR and the new VerpackDG are generating a great deal of discussion in e-commerce and other industries. Companies now need to take several new requirements into account.
You are also welcome to contact us if you need support in other countries. The ecosistant expert team can provide a service solution tailored to your company and its specific needs.
For a free step-by-step guide to registration in Germany, click here.
Interested in fully outsourcing your compliance obligations?
We are here to help. Feel free to inquire without any cost. Our team of experts will get back to you promptly.
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LUCID Packaging Register: What Online Retailers Need to Know in 2026
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EU packaging regulation 2025/40 PPWR: what does it mean for e-commerce?
The first provisions of the EU Packaging Regulation (PPWR) started applying from August 12, 2026. These include the obligation to use compliant packaging, follow rules on producer responsibility and appoint Authorized Representatives. We have summarized the most important points for online retailers here.