September 14, 2026
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New rules for producers of transport and commercial packaging
On 17 July, Germany published the Packaging Law Implementation Act (VerpackDG), which replaces the Packaging Act (VerpackG) with effect from 12 August and aligns national packaging legislation with the EU Packaging and Packaging Waste Regulation (PPWR).
The existing dual scheme for packaging that typically arises in private households (so-called “system participation packaging”) and comparable points of generation remains largely unchanged.
However, the new legislation introduces several important changes:
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Non-system participation packaging, such as transport or commercial packaging:
From 1 January 2028, producers of packaging that is not subject to system participation requirements, including many transport and commercial packaging types, must either transfer their EPR obligations to an authorised alternative producer responsibility organisation (sOfH) or obtain approval from the Central Agency Packaging Register (ZSVR) to fulfil their obligations individually. Alternative producer responsibility organisations must also be approved by the ZSVR and comply with requirements relating to collection, financial controls and financial guarantees. -
Dual schemes:
Existing producer responsibility organisations (PROs) for system participation packaging (household packaging) will continue to be approved by the competent state authorities but must meet additional operational and financial requirements, including adequate sorting and recycling capacities and financial guarantees. Higher recycling targets will apply from 2028. -
Industry solutions:
The existing option for producers to organise the take-back of certain packaging from commercial and institutional sources themselves will remain in place. However, these schemes will in future require approval from the ZSVR. Without approval, industry solutions may only continue to operate until 31 October 2027. -
Packaging waste prevention:
Dual systems, alternative producer responsibility organisations (sOfHs), industry solutions and individually obligated producers must implement and annually document measures to prevent packaging waste. This includes measures to promote reusable and refill systems. -
Foreign producers:
Producers without an establishment in Germany who sell directly to end users in Germany must appoint an Authorised Representative (AR). -
LUCID:
Existing registrations remain valid. However, producers must update their registration data by 12 November 2026. Producers newly subject to registration requirements must register by 12 September 2026.
Landbell supports you in meeting these new obligations. In the Click & Comply Shop, you can find solutions such as the Authorised Representative Service for foreign producers and service packages for transport packaging (non-system participation packaging).
