Germany
Extended producer responsibility (EPR) for packaging in Germany
Germany’s Packaging Act (Verpackungsgesetz – VerpackG) makes every company that first places sales or service packaging on the German market finance its collection and recycling. The law is enforced by the Zentrale Stelle Verpackungsregister (ZSVR), which operates the public LUCID register. Compliance with EPR Germany rules is therefore a pre-condition for selling packaged goods into the country.Who must register for packaging EPR in Germany
All manufacturers and retailers are obligated by the provisions of the new German Packaging Act, and the regulations, therefore, apply to all who deliver packaging to Germany:- Online shop operators, including small retailers who use sales and/or transport packaging to ship the goods sold
- Marketplace traders
- Stationary dealers
- Producers
- Importers
- Intermediaries
What the package includes
The scheme covers every type of sales or grouped packaging that typically ends up at private households or comparable collection points, regardless of material: paper/cardboard, plastics, glass, metals (steel, aluminium), composites, wood, etc. Transport packaging that never reaches end-consumers is outside this stream.
- paper
- paper bags
- plastics
- non-returnable containers made of glass
- beverage cartons
- aluminum
- ferrous metals or other packaging based on copper
- wool
- ceramics
- wood and
- rubber
Thresholds
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No de-minimis exemption for registration or system‐participation: a single package triggers EPR packaging Germany duties.
Declaration-of-completeness thresholds (audited report due 15 May):
- 80 t glass
- 50 t paper/cardboard
- 30 t plastics + metals + composites combined
EPR registration procedure in Germany
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Register in the LUCID portal and list all brand names – this creates your public EPR number (EPR registration Germany)
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Sign a contract with a dual system (e.g., Interzero +, Der Grüne Punkt) and pre-pay recycling fees based on forecast weights
- Report packaging volumes to both the dual system and LUCID: initial forecast, ongoing monthly/quarterly updates, year-end statement by 15 May of the following year
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Keep all records for five years; ZSVR and state authorities may request them at any time
Authorized representative
Since 3 July 2021 a producer without a German establishment may appoint a Bevollmächtigter based in Germany to fulfil VerpackG obligations (registration, reporting, fee payment) in its name. The mandate must be uploaded in LUCID before the first sale.Reporting deadline
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Ongoing volume reports – Submit either monthly or quarterly, depending on the frequency set by your dual system, for the sales period currently in progress
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Year-end volume report – For the entire previous calendar year (Year N – 1), file the report by 15 May of Year N; this requirement applies to all producers
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Audited declaration of completeness – Also due by 15 May of Year N for Year N – 1 data, but only if your volumes exceed the statutory thresholds that trigger an audit obligation
Who assumes responsibility?
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German manufacturers / packers are fully responsible as soon as a product is first placed on the German market
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Importers or intra-EU acquirers assume full liability at customs clearance or arrival—provided the packaging is not already licensed upstream
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Foreign distance sellers become liable—through a Germany-based authorised representative—when they make a direct B2C sale to a German consumer
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Dual systems (e.g., Interzero +) take on the operational duties of collection, recycling and data reporting once the membership contract is signed
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ZSVR maintains the central register and enforces compliance via data checks and audits.
Duties of each group
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Producers / importers: register in LUCID, contract a dual system, pay eco-fees, file all volume reports, and – if thresholds are met – submit an auditor-certified declaration of completeness
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Authorised representative: hold German address, maintain written mandate, carry out all VerpackG obligations on behalf of the foreign producer
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Dual systems: meet national recycling quotas, issue proof of participation, audit member data, and forward statistics to ZSVR – supporting Germany packaging recycling goals
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ZSVR / state authorities: maintain the public register, publish compliant-producer lists, and fine breaches up to €200 000 and sales bans
Extended producer responsibility (EPR) for EEE in Germany
In Germany, marketplaces must ensure their compliance with Extended Producer Responsibility (EPR) regulations commencing on January 1, 2023, for Electrical and Electronic Equipment (EEE). Consequently, this obligation pertains to all sales channels, not exclusively to products vended through the Marketplace.Who must register for EPR in Germany
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German manufacturers / brand-owners that first place electrical or electronic equipment (EEE) on the market
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Importers or intra-EU acquirers introducing un-registered goods
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Distance-selling companies with no German establishment (must act via an authorised representative)
What the equipment includes
ElektroG applies the EU “open-scope” of six categories:
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Temperature-exchange equipment
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Screens/monitors ≥ 100 cm²
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Lamps
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Large equipment > 50 cm
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Small equipment ≤ 50 cm
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Small IT & telecom devices ≤ 50 cm.
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Built-in or loose batteries are simultaneously subject to the Battery Act (BattG 3).
Threshold
There is no de-minimis exemption—a single device triggers EPR Germany duties. For packaging that accompanies EEE, the VerpackG declaration-of-completeness audit applies only above 30 t plastics/metals, 50 t paper or 80 t glass per year, linking EEE to Germany packaging recycling obligations.EPR registration procedure in Germany
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Open a producer account in the Stiftung ear portal and file a “WEEE” application for each brand & device type; the register issues a WEEE-Reg-Nr. that must appear on invoices, websites and customs documents
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Household devices: order an insolvency-proof recycling guarantee and choose a take-back logistics provider
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Submit put-on-market forecasts and pay the annual handling fee - this completes EPR registration Germany
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Keep records five years in case of UBA or Länder inspections
Authorized representative
Foreign producers must mandate a Bevollmächtigter located in Germany; the proxy files and maintains the WEEE registration, monthly reports and guarantee on the producer’s behalf. Without a valid AR, products may be blocked at customs or delisted by marketplaces.Reporting deadline
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Monthly quantity report – File the previous month’s figures by the 10th of the following month in the ear portal (stiftung-ear)
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Annual market-placement & take-back statement – Submit the full-year report for Year N-1 by 31 March of Year N in the ear portal
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Packaging volumes (VerpackG) – Send volume data to your dual system each month or quarter (as required), and lodge the year-end declaration with LUCID by 15 May via ZSVR
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Battery volumes (BattG 3) – Report quarterly figures to your battery compliance scheme, and file the annual summary with the German Environment Agency (UBA) by 30 April
Who assumes responsibility?
Responsibility for EPR compliance lies with:- Producers: Ensure EEE meets recyclability standards and report accurately
- Authorized Representatives: Act on behalf of foreign producers to fulfill obligations
- EAR Foundation: Monitors compliance and enforces regulations
Duties of each group
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Producers / importers: obtain WEEE-Reg-Nr., display crossed-out wheeled-bin symbol, join a take-back scheme, file accurate reports, pay handling & recycling fees, and retain evidence - supporting both EPR packaging Germany and EEE goals
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Authorised representative: hold German address, keep notarised mandate, submit all filings, and serve as contact for Stiftung ear EPR inspections
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Take-back / dual systems: meet national recycling quotas, issue proof of participation, audit member data, and forward statistics to authorities
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Stiftung ear & UBA: maintain public registers, publish compliant-producer lists, and impose penalties up to €100 000 or sales bans for non-compliance
Extended producer responsibility (EPR) for batteries in Germany
In Germany, starting from January 1, 2022, those engaged in the marketplace are obligated to ensure conformity with the Extended Producer Responsibility (EPR) regulations stipulated in the Batteriegesetz – BatterieG (Batteries Act).Who must register for EPR in Germany
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German manufacturers/brand-owners that first place loose or built-in batteries on the German market
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Importers/intra-EU acquirers bringing in un-registered batteries or battery-equipped products
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Distance sellers with no German establishment (mandatory authorised representative from 18 Aug 2025)
What the batteries EPR in Germany include
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Portable batteries
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SLI batteries
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Industrial & EV batteries
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Light-mobility (LMT) batteries
Threshold
There is no de-minimis exemption: marketing even one battery or battery-equipped device triggers EPR registration Germany. Eco-fees, however, cannot be billed below €200 / year (Core requirements)EPR registration procedure in Germany
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Open a Stiftung ear account and file a BattG application for each brand/category – you receive a BattG-Reg-Nr. that must appear on invoices & customs docs
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Join an approved take-back scheme (e.g., GRS, ERP GmbH, CCR Rebat) or set up an individual “Organisation für Herstellerverantwortung” (OfH) before 18 Aug 2025
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Appoint an authorised representative if you are a non-German entity – mandate must be lodged in the ear portal (compulsory from 18 Aug 2025)
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Notify UBA electronically and keep technical/financial records for five years
Authorized representative
From 18 Aug 2025 all foreign producers must designate a German-based Bevollmächtigter to carry out registration, reporting, guarantee and take-back on their behalf; without an AR, listings may be blocked and goods stopped at customsReporting deadline
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Quarterly volume report to your take-back scheme – Send the previous quarter’s battery volumes by the 15th of the month that follows each quarter, as required under BattG § 7
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Annual mass-balance report to the German Environment Agency (UBA) – File the full-year statement by 30 April of the next calendar year (N + 1), in line with BattG § 15
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Year-end packaging report (device boxes) under the VerpackG – Submit the packaging volumes for the preceding year to the LUCID register no later than 15 May of year N + 1, in accordance with VerpackG § 11
Who assumes responsibility?
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German manufacturers / packers are fully responsible as soon as a product is first sold on the German market
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Importers or intra-EU acquirers assume full liability at customs clearance, provided the item has not already been registered upstream
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Foreign distance sellers become liable—acting through a Germany-based authorised representative—when they dispatch a direct B2C shipment to a German consumer
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Take-back systems (e.g., GRS) take on the operational duties of collection, recycling and reporting from the moment the membership contract is signed
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Stiftung ear / the German Environment Agency (UBA) maintain the central registry and enforce compliance through data checks, audits and fines
Duties of each group
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Producers / importers: obtain BattG-Reg-Nr., join a take-back system, pay eco-fees, label batteries with crossed-out bin & chemistry symbols, file quarterly & annual data, and keep evidence – supporting Germany packaging recycling where applicable
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Authorised representative: hold German address, maintain notarised mandate, submit all filings, provide insolvency-proof guarantee for portable batteries
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Take-back systems / OfH: meet German and EU collection & recycling targets (63 % portable by 2027), audit member data, forward statistics to UBA
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Stiftung ear / UBA: publish the public register, cross-check reports, impose administrative fines and order sales bans for breaches