PPWR seit 12. August 2026 – was für Verkäufer gilt

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.

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))

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.

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.

Sources

This article reflects the position as at 17 September 2026 and does not constitute legal advice.

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