PPWR and VerpackDG: what companies supplying B2B packaging to Germany need to know
· Legal status: October 2026
This article gives a general overview of the rules. Whether and which obligations apply to a particular company depends on its situation and requires an individual assessment.
Since 12 August 2026, two legal acts on packaging have applied in Germany at the same time: the EU regulation PPWR (EU) 2025/40 and the new German VerpackDG, which replaced the previous VerpackG.
We often come across the assumption that B2B packaging is treated the same way as consumer packaging because PPWR covers all packaging. In Germany, however, the details are regulated by VerpackDG, which has different rules for B2B packaging than for packaging that ends up in private households. In this article we show how the two legal acts complement each other.
Who is responsible for what
PPWR sets the requirements for packaging throughout the EU, VerpackDG determines how extended producer responsibility (EPR) is implemented in Germany, and supervision lies with ZSVR and the federal state authorities.
| Level | Legal act / body | Task |
|---|---|---|
| EU | PPWR (2025/40) | Packaging requirements: substances, recycling, labelling, documentation. Extended producer responsibility, producer register and authorised representative |
| Germany | VerpackDG | Implementation of EPR in Germany: registration in LUCID, authorised representative, dual system, take-back of B2B packaging, approvals, sanctions |
| Authorities | ZSVR and federal state authorities | ZSVR runs the LUCID register and monitors, among others, registration, system participation and approvals. The documentation of B2B packaging take-back is checked by the federal state authorities |
Why do PPWR and VerpackDG look different?
The two legal acts do not exclude each other: PPWR establishes producer responsibility for packaging, VerpackDG determines how it is fulfilled in Germany.
What PPWR says. Producers bear extended responsibility for packaging they make available in a Member State for the first time. PPWR does not exclude B2B packaging from this (Art. 45(1)). How this responsibility is fulfilled (systems, approvals, organisations) is regulated by national law.
What VerpackDG says. The law divides packaging into two groups:
- Packaging that typically ends up, across the market, at private households and comparable sources (e.g. restaurants and catering, hotels, hospitals, public authorities, schools) – in principle subject to system participation (§ 3(6), § 7).
- Other packaging, e.g. purely industrial packaging and transport packaging – in principle without system participation, but with the obligation of free take-back, recovery and documentation (§ 39). From 1 January 2028, the law additionally requires approval by ZSVR or participation in a producer responsibility organisation (§ 19, § 68(9)).
Under § 6 VerpackDG, the producer registers in LUCID regardless of whether its packaging is subject to system participation – i.e. also for B2B packaging. Companies without an establishment in Germany that are producers within the meaning of the rules must appoint an authorised representative under § 5 VerpackDG. ZSVR states the same on its website: "Companies without a branch in Germany must appoint an authorised representative" (verpackungsregister.org/hilfe).
B2B packaging: obligations under PPWR and VerpackDG
The overview below summarises the rules. The "In practice" column describes typical situations and does not replace an assessment of the individual case.
| Topic | PPWR | VerpackDG | In practice |
|---|---|---|---|
| Who is the producer | Simplified: a company from another EU country or from a third country that makes packaging or packaged goods available in a country for the first time directly to end users – to consumers or to companies that use the goods themselves (Art. 3(15)(c) and (d), (23)) | Adopts the PPWR definition (§ 3(1)) | Who is the producer depends on the supply chain. For deliveries directly to end users in Germany, the producer is usually the foreign supplier; when selling to a German wholesaler who resells – usually the wholesaler |
| Registration in LUCID | Registration obligation in every country; without registration no packaging may be made available (Art. 44(2) and (4)) | Before the first making available, also stating B2B packaging (§ 6). Existing registrations: new details to be added by 12.11.2026 (§ 68(2)) | Applies to companies that are producers in Germany |
| Authorised representative | Provided for producers from another EU country who deliver directly to end users; Member States may require it from companies from third countries (Art. 45(3)) | Required for producers without an establishment in Germany, before the first making available. Written mandate in German, one authorised representative per producer, the appointment in LUCID is confirmed by ZSVR (§ 5) | According to ZSVR, companies without an establishment in Germany must appoint an authorised representative. The first question is therefore whether the company is a producer in Germany |
| Take-back of B2B packaging | General producer responsibility (Art. 45) | Free take-back of packaging not subject to system participation at or near the place of handover, reuse or recovery; a different place and costs can be agreed with business customers (§ 39(1) and (3)) | Take-back can be regulated in the contract with the customer |
| B2B documentation | – | Every year by 15 May, documentation for the previous year by material and weight: how much was made available, taken back and recovered; to be presented at the request of the federal state authority (§ 39(3)) | A running record of quantities by material (e.g. cardboard, film, wood) helps |
| Declaration of Completeness | – | For producers of packaging subject to system participation that made available at least 80 t glass, 50 t paper and paperboard or 30 t other materials in the previous year; deadline 15 May; ZSVR can request it at any time (§ 10) | Concerns packaging subject to system participation; usually not applicable to purely industrial packaging |
| Declaration of conformity | Obligation of the packaging manufacturer, regardless of B2B or B2C (Art. 38–39) | Signed EU declaration of conformity in German or English, translation into German at the authority's request (§ 62) | The declaration is issued by the packaging manufacturer; it can be requested from the supplier |
| Packaging requirements | Among others heavy metals, PFAS in food packaging, minimisation; later labelling and reuse targets for transport packaging | Enforces the PPWR requirements | Also apply to B2B packaging |
| Sanctions | Set by the Member States | Fines for breaches of VerpackDG (e.g. missing registration, missing take-back) apply since the law entered into force; fines for breaches of PPWR itself from 12.02.2027 (§ 66, § 68(17)) | – |
B2B is not only a question of the customer
Selling on invoice to another company does not automatically mean that the packaging is exempt from system participation under VerpackDG. What matters is where the type of packaging typically ends up after use, considering the entire market for such packaging.
Sources comparable to private households include restaurants, cafés, canteens, hotels, administrations, hospitals, schools, charitable institutions, freelancers, cinemas, museums and stadiums. This also includes farms and craft businesses if their packaging waste can be collected in standard collection containers (max. 1,100 l per waste fraction) (§ 3(7)).
For such packaging, a sector-specific solution is also possible instead of a dual system (§ 8). Every case requires an individual assessment.
Key dates
The dates result from PPWR and the transitional provisions of VerpackDG. The next date is 12 November 2026.
| Date | What happens |
|---|---|
| 12.08.2026 | PPWR applies throughout the EU, VerpackDG replaces VerpackG |
| 12.11.2026 | New details to be added to existing LUCID registrations |
| 31.12.2026 | Latest end of previous contracts with dual systems |
| 12.02.2027 | Sanctions for breaches of PPWR apply |
| 01.01.2028 | Approval by ZSVR or producer responsibility organisation for packaging not subject to system participation |
| 15 May (every year) | Documentation of B2B packaging take-back and Declaration of Completeness (if thresholds are reached) |
Frequently asked questions
I only deliver pallets and transport cartons to Germany. Do I have obligations?
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That mainly depends on whether your company is a producer in Germany, i.e. whether it delivers directly to end users (including companies). If so, the rules require registration in LUCID (§ 6 VerpackDG) and, for companies without an establishment in Germany, the appointment of an authorised representative (§ 5 VerpackDG; ZSVR states the same). Purely transport packaging is in principle not subject to system participation, but take-back and documentation apply and, from 1.01.2028, approval by ZSVR or participation in a producer responsibility organisation.
I sell both to wholesalers and to restaurants. What then?
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For deliveries to a German wholesaler who resells the goods, the producer is usually the wholesaler. For deliveries directly to restaurants, the producer is usually the supplier, and packaging that ends up in catering is in principle subject to system participation (or falls under a sector-specific solution). In this case the quantities must be split between the two groups and stated correctly in LUCID.
Important notice
This article is for information only and presents the rules in simplified form. It is not legal advice and not an assessment of the situation of any particular company. Whether a company is a producer and which obligations apply to it must be determined by the company itself; a binding assessment can be given by ZSVR or a lawyer. The rules and their interpretation may change. PPWR Partner is not a law firm and is not liable for decisions made solely on the basis of this article. If you need a binding answer, we can contact a German lawyer and ZSVR on your behalf on request – write to us.
Legal status: October 2026 (PPWR – Regulation (EU) 2025/40; VerpackDG – Packaging Law Implementation Act, BGBl. 2026 I No. 207).