EPR Registration with Authority
Required. Mandatory registration with the Zentrale Stelle Verpackungsregister (ZSVR) in the LUCID Packaging Register.
EPR Scheme / PRO
Competing PROs
Are PROs legally required to have a not-for-profit objective?
No
Authorised Representative
Required for producers established outside Germany
AR applicable date
12 August 2026.
Packaging Covered
Both B2C and B2B flows can be relevant. The decisive factor for system participation is not simply the sales channel, but where packaging of that type typically becomes waste. Packaging that typically accumulates mainly with private households or comparable sources is system-participation packaging. Commercial/industrial packaging outside that category is not system-participation packaging but remains subject to producer take-back and recovery obligations under the VerpackDG.
De-minimis Threshold
No threshold
Small Producer / SME Rules
No general SME exemption
Reporting Frequency (depending upon volume)
Monthly / Quarterly / Annual. Reporting frequency normally follows the frequency agreed with the dual system. For <10 tonnes/year of system-participating packaging, a simplified annual reporting option is generally available.
Reporting Period
Calendar year
Applicable?
Yes (in future). Section 26 VerpackDG requires system operators to build ecological incentives into participation fees for system-participation packaging. The incentives must promote packaging that can be recycled to the highest possible percentage in real sorting/recovery practice and the use of recyclates and renewable raw materials. Germany does not prescribe one uniform national euro-per-kg bonus/malus table: individual systems set their participation prices within the legal framework.
Effective Date
The ecological-incentive principle existed previously under section 21 VerpackG and continues under section 26 VerpackDG from 12 August 2026. As of 18 August 2026, ZSVR’s published legally relevant recyclability methodology is the 2025 Minimum Standard; the 2026 edition is subject to the annual update cycle and must be published by 1 September under the VerpackDG.
Criteria
Core eco-modulation criteria are: (1) recyclability based on actual sorting and recovery practice, assessed using the ZSVR Minimum Standard; (2) use of recycled materials; and (3) use of renewable raw materials. The minimum standard is material- and recovery-route specific and is updated annually by ZSVR in agreement with the German Environment Agency. The precise financial incentive model and tariff levels remain system-specific, subject to the statutory framework and future implementing ordinances under section 26a VerpackDG.