The VerpackDG is the Verpackungsrecht-Durchführungsgesetz of 13 July 2026, the German law implementing Regulation (EU) 2025/40 on packaging. It entered into force on 12 August 2026, the day the EU’s Packaging and Packaging Waste Regulation (PPWR) started to apply, and the two together replaced the Verpackungsgesetz (VerpackG). The PPWR sets the rules for the packaging itself; the VerpackDG sets how extended producer responsibility works in Germany. Sources, both in German: the law text and the packaging register’s overview of what has applied since 12 August 2026.
What the VerpackDG Regulates
The VerpackDG decides who pays for collecting and recycling packaging in Germany and how that is checked. The core duties stayed the same as under the old law: registration, system participation and data reports. What changed is the logic that decides who carries them.
The competent authority is the Zentrale Stelle Verpackungsregister (ZSVR), which runs the LUCID register. Breaches are fined up to 10,000, 100,000 or 200,000 euros, depending on the duty (section 66, paragraph 3).
Producer and Manufacturer
The PPWR separates two roles. The manufacturer, called Erzeuger in the German text, answers for the packaging’s conformity. The producer, called Hersteller, carries extended producer responsibility in the country where the packaging becomes waste, and that is the role the VerpackDG addresses.
The brand comes first. A company that has packaging or packaged products made under its own name or brand is the manufacturer. If that manufacturer is based in Germany, it is also the producer here, according to ZSVR. A German club that orders gift boxes printed with its crest for a pin set is therefore both. Our PPWR glossary entry covers the manufacturer’s side.
Registration in LUCID
Producers must register with the ZSVR before they first make packaging available in Germany (section 6). The registration names, among other things, the brand names under which the producer places packaging on the market and the types of packaging, and the ZSVR publishes registered producers online.
Registration and data reports in LUCID are free, according to the ZSVR’s help page on system participation. The producer must register itself: an authorised representative or another third party can take over other duties, but not this one. Who registers for which merchandise item is set out step by step in our guide to packaging EPR and LUCID registration for merchandise.
System Participation, the “Packaging Licence”
Packaging that typically ends up as waste in private households or comparable places, plus all service packaging, is system-obligated (section 3, paragraph 6). Its producer must join one or more dual systems before making it available and state the material type and weight (section 7). The ZSVR adds that shipping packaging is system-obligated without exception (page on mail order and online retail).
This paid contract with a system operator is what German searchers call a Verpackungslizenz, a “packaging licence”, and the ZSVR uses the word itself on the same help page. Am Ball, a Munich-based design, licensing and production-management agency for official collectibles and merchandise, is registered in LUCID and holds a Der Grüne Punkt licence for the packaging it places on the market as producer.
What Changed From the Verpackungsgesetz
Registrations under the old law stay valid, and the law gives registered producers until 12 November 2026 to report changes, such as new brand names (section 68, paragraph 2). System participations concluded under the old law continue until 31 December 2026 and no longer (paragraph 1); our LUCID guide explains which producers can rely on that.
Two duties are new. Producers based abroad without a German establishment that deliver directly to end users in Germany must appoint an authorised representative. Producers of packaging that needs no system participation may work without a ZSVR approval until 31 December 2027 and need one from then on (section 68, paragraph 9).
Frequently Asked Questions
Is the VerpackDG the same as the Verpackungsgesetz?
No. The VerpackDG replaced the Verpackungsgesetz on 12 August 2026. Registration, system participation and data reports remain, but who must carry them now follows the PPWR’s roles of manufacturer and producer.
What is a Verpackungslizenz?
It is the everyday German word for system participation: a paid contract with a dual system that finances the collection and recycling of your packaging. Registration in LUCID is a separate, free step with the ZSVR, and you need both.
Do sellers based outside Germany have to register?
Yes, when they are the producer, for example because they deliver directly to end users in Germany. They must also appoint an authorised representative in Germany, while the LUCID registration remains their own duty.
Does the VerpackDG apply to merchandise packaging?
Yes. A gift box or bag that ends up in a fan’s home is the kind of sales packaging the law makes system-obligated, and every shipping carton sent to customers is too. For items in doubt, the ZSVR’s catalogue of system-obligated packaging decides.
<nav class="article-breadcrumb"><a href="https://www.amball.com/magazine">Magazine</a><span class="article-breadcrumb__sep">/</span><a href="https://www.amball.com/glossary">Glossary</a><span class="article-breadcrumb__sep">/</span><span class="article-breadcrumb__current">VerpackDG (German Packaging Law Implementation Act)</span></nav> <h1 class="article-h1">VerpackDG (German Packaging Law Implementation Act)</h1> <p class="article-byline"><span class="cluster-badge">Licensing, Manufacturing & Compliance</span> · Updated October 19, 2026</p> <div class="article-intro"><p>The VerpackDG, Germany's Verpackungsrecht-Durchführungsgesetz, is the national packaging law that works alongside the EU's PPWR. Since 12 August 2026 it has set the rules for producer registration, system participation and reporting in Germany.</p></div> <ul><li>The VerpackDG entered into force on 12 August 2026 and, together with the EU’s PPWR, replaced the German Verpackungsgesetz (VerpackG).</li><li>The producer must register with the Zentrale Stelle Verpackungsregister in LUCID before first making packaging available in Germany, and registration is free.</li><li>Packaging that typically ends up with households, all service packaging and all shipping packaging needs a paid system participation with a dual system.</li></ul><p>The VerpackDG is the Verpackungsrecht-Durchführungsgesetz of 13 July 2026, the German law implementing Regulation (EU) 2025/40 on packaging. It entered into force on 12 August 2026, the day the EU’s Packaging and Packaging Waste Regulation (PPWR) started to apply, and the two together replaced the Verpackungsgesetz (VerpackG). The PPWR sets the rules for the packaging itself; the VerpackDG sets how extended producer responsibility works in Germany. Sources, both in German: the <a href="https://www.gesetze-im-internet.de/verpackdg/">law text</a> and the <a href="https://www.verpackungsregister.org/ich-moechte-wissen-was-seit-dem-12-august-2026-gilt">packaging register’s overview of what has applied since 12 August 2026</a>.</p><h2>What the VerpackDG Regulates</h2><p>The VerpackDG decides who pays for collecting and recycling packaging in Germany and how that is checked. The core duties stayed the same as under the old law: registration, system participation and data reports. What changed is the logic that decides who carries them.</p><p>The competent authority is the Zentrale Stelle Verpackungsregister (ZSVR), which runs the LUCID register. Breaches are fined up to 10,000, 100,000 or 200,000 euros, depending on the duty (<a href="https://www.gesetze-im-internet.de/verpackdg/__66.html">section 66</a>, paragraph 3).</p><h2>Producer and Manufacturer</h2><p>The PPWR separates two roles. The manufacturer, called Erzeuger in the German text, answers for the packaging’s conformity. The producer, called Hersteller, carries extended producer responsibility in the country where the packaging becomes waste, and that is the role the VerpackDG addresses.</p><p>The brand comes first. A company that has packaging or packaged products made under its own name or brand is the manufacturer. If that manufacturer is based in Germany, it is also the producer here, according to <a href="https://www.verpackungsregister.org/erste-schritte/abgrenzung-erzeuger-hersteller">ZSVR</a>. A German club that orders gift boxes printed with its crest for a pin set is therefore both. Our <a href="https://www.amball.com/glossary/ppwr">PPWR glossary entry</a> covers the manufacturer’s side.</p><h2>Registration in LUCID</h2><p>Producers must register with the ZSVR before they first make packaging available in Germany (<a href="https://www.gesetze-im-internet.de/verpackdg/__6.html">section 6</a>). The registration names, among other things, the brand names under which the producer places packaging on the market and the types of packaging, and the ZSVR publishes registered producers online.</p><p>Registration and data reports in LUCID are free, according to the ZSVR’s <a href="https://www.verpackungsregister.org/hilfe/systembeteiligung-katalog">help page on system participation</a>. The producer must register itself: an authorised representative or another third party can take over other duties, but not this one. Who registers for which merchandise item is set out step by step in our <a href="https://www.amball.com/magazine/packaging-epr-merchandise-lucid-registration">guide to packaging EPR and LUCID registration for merchandise</a>.</p><h2>System Participation, the “Packaging Licence”</h2><p>Packaging that typically ends up as waste in private households or comparable places, plus all service packaging, is system-obligated (<a href="https://www.gesetze-im-internet.de/verpackdg/__3.html">section 3</a>, paragraph 6). Its producer must join one or more dual systems before making it available and state the material type and weight (<a href="https://www.gesetze-im-internet.de/verpackdg/__7.html">section 7</a>). The ZSVR adds that shipping packaging is system-obligated without exception (<a href="https://www.verpackungsregister.org/themen/versand-und-onlinehandel">page on mail order and online retail</a>).</p><p>This paid contract with a system operator is what German searchers call a Verpackungslizenz, a “packaging licence”, and the ZSVR uses the word itself on the same help page. Am Ball, a Munich-based design, licensing and production-management agency for official collectibles and merchandise, is registered in LUCID and holds a Der Grüne Punkt licence for the packaging it places on the market as producer.</p><h2>What Changed From the Verpackungsgesetz</h2><p>Registrations under the old law stay valid, and the law gives registered producers until 12 November 2026 to report changes, such as new brand names (<a href="https://www.gesetze-im-internet.de/verpackdg/__68.html">section 68</a>, paragraph 2). System participations concluded under the old law continue until 31 December 2026 and no longer (paragraph 1); our LUCID guide explains which producers can rely on that.</p><p>Two duties are new. Producers based abroad without a German establishment that deliver directly to end users in Germany must appoint an authorised representative. Producers of packaging that needs no system participation may work without a ZSVR approval until 31 December 2027 and need one from then on (section 68, paragraph 9).</p><h2 id="frequently-asked-questions">Frequently Asked Questions</h2><h3>Is the VerpackDG the same as the Verpackungsgesetz?</h3><p>No. The VerpackDG replaced the Verpackungsgesetz on 12 August 2026. Registration, system participation and data reports remain, but who must carry them now follows the PPWR’s roles of manufacturer and producer.</p><h3>What is a Verpackungslizenz?</h3><p>It is the everyday German word for system participation: a paid contract with a dual system that finances the collection and recycling of your packaging. Registration in LUCID is a separate, free step with the ZSVR, and you need both.</p><h3>Do sellers based outside Germany have to register?</h3><p>Yes, when they are the producer, for example because they deliver directly to end users in Germany. They must also appoint an authorised representative in Germany, while the LUCID registration remains their own duty.</p><h3>Does the VerpackDG apply to merchandise packaging?</h3><p>Yes. A gift box or bag that ends up in a fan’s home is the kind of sales packaging the law makes system-obligated, and every shipping carton sent to customers is too. For items in doubt, the ZSVR’s catalogue of system-obligated packaging decides.</p><hr class="faq-end"> <section class="related-section"><h2>Related Glossary Terms</h2><div class="related-grid"><a href="https://www.amball.com/glossary/reach" class="related-card"><p class="related-label">Licensing, Manufacturing & Compliance</p><p class="related-title">REACH (EU Chemicals Regulation)</p><p class="related-snippet">REACH is the EU's core chemicals regulation, controlling which substances can be used in a product sold into the EU and how their presence has to be disclosed. For merchandise, the parts that matter most are the Substances of Very High Concern (SVHC) disclosure duty and specific Annex XVII restrictions like the nickel release limit on metal goods.</p></a><a href="https://www.amball.com/glossary/ppwr" class="related-card"><p class="related-label">Licensing, Manufacturing & Compliance</p><p class="related-title">PPWR (EU Packaging and Packaging Waste Regulation)</p><p class="related-snippet">PPWR (Regulation (EU) 2025/40) is the EU's Packaging and Packaging Waste Regulation. It applies from 12 August 2026 to all packaging placed on the EU market, including the gift boxes, polybags and cartons used for merchandise.</p></a></div></section> <section class="from-blog-section"><h2>From the Magazine</h2><a class="from-blog-link" href="https://www.amball.com/magazine/packaging-epr-merchandise-lucid-registration">Packaging EPR for Merchandise: Who Registers in LUCID?</a><a class="from-blog-link" href="https://www.amball.com/magazine/ppwr-merchandise-packaging-manufacturer">PPWR for Merchandise: Who Is the Packaging Manufacturer?</a></section>
