Packaging obligations in Germany (2026)

The core system remains in place: LUCID registration + system participation with a dual system (approved German take-back scheme). New since 12 Aug 2026: an authorised-representative requirement for foreign producers without a German establishment (until 11 Aug 2026 appointing an authorised representative was merely optional, § 35(2) VerpackG old version; the LUCID registration itself was and remains non-delegable). From 1 Jan 2028, producers of packaging not subject to system participation (e.g. transport packaging) need an approval from the ZSVR (§ 19 VerpackDG) or must transfer their obligations to an approved 'other producer responsibility organisation' (§ 22 VerpackDG; transitional periods: § 68(9) and (12)). The harmonised producer registers under Art. 44 PPWR (national registers in an EU-wide uniform format, 18 months after the first implementing act) will only follow later; the register authority in Germany is the ZSVR (§ 6(6) VerpackDG).