Importing Into Germany? Your Packaging Law Changed on 12 August 2026.

What happened?

The German Packaging Act was replaced. Packaging in Germany now runs on two texts. One is the EU packaging regulation — Regulation (EU) 2025/40, known as the PPWR. The other is a German act, the Verpackungsrecht-Durchführungsgesetz (VerpackDG). The old Verpackungsgesetz (VerpackG) is gone.

The registry puts it plainly. The basic duties — registration, system participation and data reporting — "will remain in place. What will change, however, are the rules governing who is required to fulfil these obligations and under what conditions."

Am I still registered?

Yes. If you were in LUCID on 11 August, you are in LUCID now. You still report. You still pay a dual system. None of that machinery changed.

What changed is the map of who owes what. One duty is new, and it landed on you.

What is the new duty?

You now have to hold your supplier's conformity paperwork before the goods go out. The old act was about waste. The new regulation is also about the pack itself.

Someone has to prove the pack meets the EU design rules. The regulation calls that party the manufacturer — normally whoever's brand is on the pack. Article 18 makes it your job to check they have done it, and to hold a copy.

This is the part most importers have not set up yet. The rest of this article is mostly about it.

What is LUCID, and why am I in it?

LUCID is Germany's public packaging register. It is run by the Zentrale Stelle Verpackungsregister (ZSVR). Signing up is free and takes minutes online. The number is issued at once.

You are in it because the law calls you the producer. A producer is the manufacturer, importer or distributor who "is established in a Member State and makes available for the first time from within the territory of that Member State and on that same territory" the packed goods.

Read it twice. Established in Germany. Supplying from inside Germany. Your supplier in India or Türkiye meets neither test. You meet both, because you are first in the German chain.

My supplier says they will register instead. Can they?

Not for your imports. A company outside the EU can be the producer in one case only: when it ships straight to a German end user with nobody in between. ZSVR says it in a line — "A foreign company is only considered the producer if it ships from abroad directly to a (private or commercial) end user."

A container that comes to your warehouse is not that case. You are the producer. A clause in the supply contract does not move it.

Whose brand names go in my registration?

Your suppliers'. The register lists the brand names under which a producer first makes packaging available in Germany. Those are the brands printed on the packs you bring in, not your own company name alone.

So a new supplier means a new brand in your LUCID entry. Missing brands are the most common gap we see. The register is public, and a retailer or a marketplace checking a product searches the brand — not you.

What is system participation, and what does it cost?

It is the recycling fee, and it is yours to pay. Registration is free. This is the part with a price on it.

You sign a contract with a dual system — a private operator such as Der Grüne Punkt, Interseroh or Reclay. You pay by the weight and the material of what you put on the market.

That makes your supplier's pack design your cost. A heavy multi-layer laminate is dearer than a simple one. Ask for exact pack weights by material at sampling stage. You will need those numbers every year in any case.

What is the declaration of completeness?

An audited annual return, due 15 May. It only bites above real volume. You file one if your previous-year volumes reached any of these:

• Glass — 80 tonnes
• Paper, paperboard and cardboard — 50 tonnes in total
• Ferrous metals, aluminium, plastics, beverage cartons and other composites — 30 tonnes in total

The auditor must be registered with ZSVR. The date cannot be moved. A late filing is an offence on its own. This is the other reason to hold pack weights by material all year.

What happens if I do not register?

You cannot sell, and nor can your customers. Section 13 of the VerpackDG bars a producer from supplying packaging in Germany without proper registration. It also bars supply without a system contract.

The third limb is the one that hurts. Distributors may not supply packaging if the producer is not properly registered. ZSVR spells out the effect: failing to register "results in a distribution ban for the products in question that also applies to downstream distributors."

The EU regulation says the same from the other side. Under Article 19, a distributor has to verify that the producer is on the register before it sells. Your retailer is required to check you.

What are the fines, and who issues them?

Up to €200,000, and it is a state authority that imposes them — not ZSVR. Section 66 of the VerpackDG sets three tiers:

• Up to €200,000 — failing to participate in a system, among other cases
• Up to €100,000 — failing to register, or supplying in breach of the distribution ban
• Up to €10,000 — the remaining cases

Enforcement sits with the authority named by the law of your federal state. ZSVR runs the register and monitors it. It is not the body that fines you.

What does Article 18 actually ask of me?

Four checks, all before the goods go on the market. Article 18(2) says an importer must make sure that:

• the manufacturer carried out the conformity assessment, and drew up the technical documentation set out in Annex VII
• the pack is labelled as Article 12 requires
• the required documents travel with the pack
• the manufacturer has met Article 15(5) and (6) — an identifying batch or type number, plus the manufacturer's name and postal address

And if you think a pack does not comply, you must not place it until it does.

Do I have to keep the paperwork myself?

Yes — a copy of it. Article 18(7) says an importer keeps a copy of the EU declaration of conformity available to the market surveillance authorities. Five years for single-use packaging. Ten for reusable.

You must also be able to produce the Annex VII technical file on request. Article 18(8) gives you 10 days to answer a reasoned request from an authority.

A file that sits only in a supplier's office abroad will not meet a 10-day clock. Get your copy with the first shipment, not when the letter arrives.

Does my own name have to go on the pack?

Yes, and this one changes artwork. Article 18(3) says an importer puts its name, registered trade name or trademark on the pack, with a postal address and, where there is one, an electronic contact. If it will not fit, it can go in a digital data carrier or in a document with the goods.

This sits next to the manufacturer's own details under Article 15(6). Not instead of them. Two sets of contacts on the pack, not one.

Raise it with your supplier before the next artwork run. Reprinting a pouch reel is a lot dearer than editing a file.

What if my supplier will not produce the file?

Then you cannot place the goods, and the loss is yours. Article 18(2) is a precondition, not a target. The regulation does not let you sell on a promise.

That is why this belongs in the purchase contract, not in an email thread. Ask for it the way you ask for a health certificate — as a condition of the first shipment.

Can my supplier hand this job to an agent in Europe?

Part of it, not all of it. Article 17 lets a manufacturer appoint an authorised representative by written mandate. That representative can hold the declaration and the file, deal with the authorities and answer requests.

Then the regulation draws a hard line. Drawing up the Annex VII documentation, and the duty to place only compliant packaging, "shall not form part of the authorised representative's mandate."

So a European agent can hold the file. Only the manufacturer can make it. If a supplier offers you an agent instead of a file, that is not the same thing.

Does the declaration have to be in German?

No. German or English, at the manufacturer's choice. Section 62 of the VerpackDG says a signed version must be kept "at the manufacturer's choice, either in German or English."

One caveat. If the authority asks, it has to be translated into German. And Article 18(8) says you answer in a language the authority can easily understand. So an English file on the shelf is fine. Budget for a translation if a request ever lands.

How long do I keep it?

Five years for single-use packaging. Ten for reusable. The clock runs from the date the pack was placed on the market, and it covers the technical documentation and the declaration of conformity alike. Almost everything in food and FMCG is the five-year figure.

I sell it as my own private label. What changes?

Everything on the conformity side. You become the manufacturer. Article 21 says that where an importer or distributor places packaging on the market "under its own name or trademark", that importer or distributor is treated as the manufacturer and takes on the Article 15 duties.

So on own-brand lines you do not check the file. You make it. That means the conformity assessment, the Annex VII documentation and a signed EU declaration. You keep them five or ten years. And if something is wrong, the duty to correct or recall is yours.

The same applies if you change a pack already on the market in a way that could affect compliance. Relabelling and repacking can both count.

I do both — branded imports and own label. Where does that leave me?

Two roles on the same warehouse floor. The role follows the brand on the pack, line by line.

A pack carrying your supplier's brand: they are the manufacturer, and you check. A pack carrying yours: you are the manufacturer, and you build. The same factory can fill both on the same day.

Is there any relief for a small company?

One narrow carve-out, and it rarely reaches an importer. Where the own-brand company is a micro-enterprise and the party supplying the packaging is located in the Union, the regulation moves manufacturer status to that supplier.

Both limbs have to hold. If your packaging comes from a third country, the carve-out does not apply and the file stays with you.

Must the pack carry the Green Dot?

No. It is one company's trademark, not a legal marking. This is the most persistent myth in German packaging compliance, and it costs money in both directions. Some stock arrives with it printed and no licence behind it. Some buyers think printing it proves compliance.

Der Grüne Punkt is a dual system: one of several competing operators you can contract with. Its own commercial pages separate the two things exactly — you participate in the system to meet your legal duty, and then, "by concluding a trademark license agreement, you can also use the new QR code with our well-known 'Der Grüne Punkt' trademark on your sales packaging."

What about the material codes — PET 1, ALU 41, the triangles?

Optional to apply, but if they are there they must be the official ones. Section 4 of the VerpackDG says packaging may be marked with the numbers and abbreviations in Annex 2 to identify its material — then closes the door. Using any other numbers or abbreviations for the same materials "is not permitted."

Two drafting rules sit inside the annex and are easy to miss. Abbreviations are in capitals only. A composite takes a C/ and then the abbreviation of the main material. That is why a beverage carton is C/PAP 84 and not "carton".

Does Germany have a sorting label like the French Info-tri?

Not a national one — and that is the point of what comes next. France requires the Triman and the Info-tri block on household packaging. Germany has never asked for an on-pack sorting mark. Its system is financial and administrative, not graphic.

That gap closes on 12 August 2028. Article 12 of the EU regulation will require packs to carry a harmonised pictogram label showing what they are made of, so a consumer can sort them. It applies across the EU. Transport packaging and deposit packaging are excluded.

The implementing acts that fix the pictograms are not published yet, so there is nothing to design to today. But artwork is cut once and used for years. Put the date in front of your suppliers now.

What about beverages — the Pfand?

Single-use beverage packaging is generally deposit-bearing, and the initial distributor has to label it. If you are the first to sell it in Germany, that is you. Cans and single-use plastic, glass or PET bottles for water, soft drinks, juices, beer and alcoholic mixed drinks are the standard cases.

The exemptions are narrower than people expect, and section 46(4) of the VerpackDG sets them out exhaustively. By volume, under 0.1 litre and over 3.0 litres is out. By format, beverage cartons, polyethylene tubular bags and foil stand-up pouches are out. By content, the list runs to wine and wine-based drinks, sparkling wine, spirits taxed under the Alcohol Duty Act, other alcoholic mixed drinks at 15% abv or more, and milk and dairy drinks with at least 50% milk.

Note what stays in. A fruit juice in a PET bottle is deposit-bearing. The same juice in a carton is not. And the film or tray bundling the bottles is ordinary packaging that goes into system participation.

Do the shipping carton and the pallet wrap count?

They are in scope, but they are not the same obligation as the retail pack. The rules split packaging in two. On one side, packaging that usually ends up as household waste: the pouch, the jar, the shelf-ready tray. On the other, transport packaging that piles up at a commercial address.

Household-type packaging goes into system participation and is paid for by the kilo. Transport packaging is not system-participation packaging, but it does not vanish from the law. It carries take-back and recovery duties, and your LUCID registration covers both categories. Do not assume the shipper carton is invisible.

What about goods I buy from another EU country?

Two answers, and they are different. On the recycling side you are still the producer. You are established in Germany and you make the goods available for the first time from within Germany. LUCID and the dual-system contract stay yours.

On the conformity side you are a distributor, not an importer. An importer is a person established in the Union who places packaging from a third country on the market. Goods bought from a supplier in Poland or Italy are already on the Union market, so someone else was the importer.

Article 19 asks less of you than Article 18. Verify the producer is on the register, verify the Article 12 labelling, and verify that the manufacturer's and the importer's contact details are on the pack. You do not have to hold the Annex VII file.

Is this the same rule I read about for France?

Same skeleton, different flesh — and the two moved within a month of each other. Both countries put the recycling duty on whoever first places the pack on the national market, which in an ordinary import is you. Both made a locally established representative compulsory this year for foreign sellers who supply consumers directly: France on 10 July 2026, Germany on 12 August 2026.

The differences that reach your artwork and your terms:

• France makes you print something — the Triman and the Info-tri block. Germany does not, until the EU harmonised label arrives in 2028
• France issues a 15-character unique identifier that has to appear in your terms and on your website. Germany issues a LUCID registration number and publishes it in a public register
• The conformity file is not a German invention. It comes from the EU regulation, so a French importer has the same Article 18 duty. Only the recycling schemes differ country by country

If France is also on your list, the companion piece is here: Selling in France? The Triman Is Mandatory on Your Pack.

What is coming next, and when?

Three dates worth writing down.

• 31 October 2027 / 31 December 2027 — the transition window for the new ZSVR authorisation procedure covering packaging that is not subject to system participation. Producers may operate without authorisation until the end of 2027, producer responsibility organisations until 31 October 2027. Authorisation will carry a fee
• 12 August 2028 — the harmonised EU sorting label under Article 12, or 24 months after the implementing acts, whichever falls later
• 1 January 2030 — the substantive design requirements, including minimum recycled content in plastic packaging and the packaging minimisation rules

None of these need action this quarter. They matter because packaging artwork and tooling are commissioned once and used for years. The cheapest time to know about a 2028 label is before you cut the current one.

What should I do this month?

One list from your suppliers, one from your own files.

Ask every supplier whose brand you import for three things. The signed EU declaration of conformity. The Annex VII technical documentation, or a written undertaking to produce it in 10 days. And pack weights by material.

Then check three things in your own files. That every brand you import is named in your LUCID registration. That your system participation contract covers those packs. And that your own name and address appear on them.