PPWR: What Has Applied to Sellers Since 12 August 2026

On 12 August 2026, the EU Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) and the German VerpackDG replaced the previous German Packaging Act. The good news first: the basic structure remains. What is new comes down to two points – and one of them affects every company without an establishment in Germany that sells directly to German end users.

And something else falls on that date: since 12 August 2026 Amazon has verified packaging registration not only for Germany and France, but for every EU country in which you sell or store. More on that below.

What has stayed the same

The three core duties under German packaging law remain:

• Registration in the LUCID packaging register held by the Central Agency Packaging Register (ZSVR)
• System participation for packaging subject to system participation
• Data reporting of the volumes placed on the market

One caveat: the criteria determining which packaging is subject to system participation have changed with the PPWR. A classification that was correct under the old Packaging Act does not automatically remain valid – review your packaging portfolio again.

New: manufacturer and producer are two separate roles

The PPWR separates two responsibilities that used to sit with one party. The German terms are counter-intuitive, and mixing them up means taking on the wrong obligations:

• The manufacturer (German: Erzeuger) is whoever is responsible for the design and composition of the complete packaging. They must ensure the conformity of the packaging: technical documentation and a declaration of conformity.
• The producer (German: Hersteller) carries extended producer responsibility (EPR) in the member state where the packaging becomes waste, and finances the disposal of packaging waste.

Who holds the producer role depends on the supply chain – it may be the manufacturer, the importer or the distributor. For online sellers shipping from abroad directly to German consumers the answer is usually clear: you are the producer for EPR purposes, and depending on how your packaging is designed, the manufacturer as well.

New: authorised representative required for foreign producers

This is the most important practical change. Companies based abroad and without an establishment in Germany that supply empty packaging or packaged products directly to end users in Germany have been obliged since 12 August 2026 to appoint an authorised representative.

One exception matters a great deal: registration in LUCID remains the producer's personal duty. That single obligation cannot be delegated to the authorised representative – unlike under the ElektroG, where the representative assumes every obligation. Get this wrong and you end up without a valid registration.

Everything else is handled by the representative: system participation contracts, volume and data reports, declarations of completeness, take-back duties and participation in the deposit system.

Requirements for the authorised representative

• registered office or establishment in Germany
• a written contract in German – the German version is legally binding
• signed by hand or with a qualified electronic signature
• a separate LUCID login as an authorised representative
• must be an external service; the producer's own employees do not qualify
• only one authorised representative is permitted per company

The ZSVR does not publish a list of approved representatives. Vetting the service provider is up to you.

Product requirements: what manufacturers must now demonstrate

• Conformity assessment of the packaging against the sustainability requirements in Articles 5 to 12 PPWR
• A declaration of conformity for each packaging type, plus technical documentation to be kept available for requests from the authorities
• Substance restrictions, including PFAS limits for food-contact packaging (Article 5(5))

Not just Germany: 12 August applies EU-wide

Amazon's choice of that particular date is no coincidence. Since 12 August 2026 the marketplace has verified packaging EPR in every EU country in which you sell or store. For batteries, country-specific registration has been mandatory since 18 August 2025.

Three points are regularly underestimated:

• Every country runs its own register. Your LUCID registration has no effect in France or Italy. There you need your own number – in France, for example, the Identifiant Unique (IDU) issued by ADEME.
• Every waste stream counts separately. Shipping an electrical device in a cardboard box places two waste streams on the market and requires two registrations per country, not one.
• Storing counts as selling. If your goods sit in a marketplace warehouse abroad, the registration obligation applies there – even without a single sale in that country.

The real bottleneck is not the obligation but the lead time. Processing takes from two weeks in the Netherlands to four months in Austria. Anyone who only starts after a listing has been blocked loses that entire period as lost revenue.

Registrations by country

For these countries you can book registration directly with us – with open prices, stated processing times and an explicit note on which amounts are not included:

• France – since 10 July 2026 an authorised representative is mandatory for all waste streams (Art. L. 541-10-9-1 code de l'environnement)
• Italy – longer processing times, bundle for electrical equipment and batteries
• Spain – Hague apostille included; photovoltaic modules form their own category
• Netherlands – no authorised representative for EU-based companies (still under discussion for non-EU companies), registration in 2–4 weeks
• Belgium – reporting frequency differs by waste stream
• Poland – authorised representative, BDO registration (AR registration number) and PRO membership included, e-commerce only
• Sweden – monthly reporting for electrical equipment and batteries
• Ireland – electrical equipment and batteries priced by annual turnover rather than volume; packaging by company location, turnover and volume
• Austria – longest lead time: three to four months
• Germany – ElektroG, BattDG, VerpackDG and EWKFondsG

For a full overview see Amazon EPR mandatory countries; all prices are on the price overview.

What is still to come by 2027

Packaging not subject to system participation will require an authorisation from the ZSVR. Under the transitional rules, other producer responsibility organisations (sOfH) may operate without that authorisation until 31 October 2027, and producers until 31 December 2027.

Your next steps

1. Clarify your role: are you the producer, the manufacturer – or both?
2. Check and update your LUCID registration (brands, packaging types).
3. No establishment in Germany? Appoint an authorised representative – in writing, in German.
4. Reconcile system participation and data reporting for the current year.
5. For packaging you have designed: build up the declaration of conformity and technical documentation.
6. Above certain volumes, plan for a declaration of completeness by a registered auditor.
7. Go through your other EU markets: in which countries do you sell or store? Each one needs its own registration per waste stream.

How we help

ECOPV-EU GmbH handles packaging compliance for the German market – from classifying your role through system participation to the declaration of completeness. See Packaging (VerpackDG / PPWR) for an overview; all prices are listed openly on our price overview.

Affected by more than packaging? We also cover Electrical equipment (ElektroG / WEEE), Batteries (BattDG) and Single-use plastics (EWKFondsG) – from a single source if you wish. Not sure what applies to you? Get in touch or book a compliance check.

Why ECOPV-EU GmbH

• In business since 2020 – six years of EPR practice, not a side line.
• More than 20,000 sellers worldwide trust us with their EPR compliance.
• EPR in more than 20 European countries – in over ten of them through our own group companies on the ground rather than intermediaries. No third party sits in the chain.
• Approved ElektroG authorised representative – listed in the stiftung ear list of approved ElektroG authorised representatives (Liste der zugelassenen ElektroG-Bevollmächtigten).
• Our own approved manufacturer guarantee system – listed in the stiftung ear list of approved manufacturer guarantee systems (Liste zugelassene Herstellergarantiesysteme) under the system name Authorized Representative Guarantee.
• Our own producer responsibility organisation (OfH) under § 8 BattDG – representation and take-back from a single source.
• Provider in the Amazon Service Provider Network (SPN) and official Temu service partner.

Sources

• ZSVR: What has applied since 12 August 2026
• ZSVR: Authorised representation
• ZSVR: Roles and obligations
• Légifrance: Art. L. 541-10-9-1 code de l'environnement

This article reflects the position as at 18 September 2026 and does not constitute legal advice.