Packaging Compliance in Germany and Austria: VerpackDG, LUCID and Reuse Rules

What changed in Germany on 12 August 2026: from VerpackG to VerpackDG

The VerpackDG replaced the VerpackG from 12 August 2026. The PPWR now applies directly to packaging design and labelling, while the VerpackDG organises the German EPR system around it: LUCID registration, participation in a dual system before placing packaging on the market, and the rules for service packaging. For most foodservice businesses the familiar duties continue under the new law.

What stays the same in practice:

• Registration in LUCID, the register run by the ZSVR, remains mandatory and cannot be delegated to a third party.
• System participation (Systembeteiligung) with a licensed dual system must be in place before packaging that ends up with private end consumers is placed on the market.
• Service packaging (Serviceverpackungen), meaning packaging filled at the point of sale such as takeaway bags, cups, wraps and boxes, follows new producer rules: according to the ZSVR, buying pre-licensed (vorbeteiligte) service packaging is no longer possible in most cases.

What is new is the role definition. The PPWR defines the manufacturer as whoever has packaging designed or manufactured under its own name or trademark. German market commentary, including a supplier note published in August 2026, states that from 12 August 2026 the brand owner of custom-printed packaging is the producer and that the supplier provides material and weight data. That is consistent with the PPWR definition, but check how ZSVR guidance applies it to your situation. The PPWR itself is explained in our PPWR guide for foodservice and e-commerce buyers.

Who must register in LUCID and license packaging in Germany?

The business that first places system-relevant packaging on the German market, typically the brand owner, chain or importer, must register in LUCID and license the packaging with a dual system. Registration is always the company's own task. For service packaging, who is the producer now depends mainly on whose name, logo or brand is on it, and shifting licensing to an upstream supplier is possible only in two narrow cases (see below).

Restaurant chain or brand owner

If you hand customers packaging printed with your brand, plan on being treated as the producer. According to the ZSVR, if you buy service packaging bearing your name, logo or brand, you are both manufacturer (Erzeuger) and producer (Hersteller) under the PPWR, wherever the supplier is based, so you must register in LUCID under your own name, list your brand names and license the packaging with a dual system yourself; pre-licensing by the supplier is not available for such packaging. The exception is a micro-enterprise (fewer than 10 staff and no more than EUR 2 million turnover or balance sheet) whose supplier is established in the same Member State: that supplier is then the manufacturer and producer. Franchise systems should agree in writing whether the franchisor or each franchisee registers and licenses, because the answer depends on whose name is on the packaging and who places it on the market.

Importer

A German importer of unfilled printed packaging or packed goods is often the first party placing that packaging on the German market. It then carries the LUCID and licensing duties unless they are clearly assigned elsewhere. Importers of single-use plastic products also usually carry the Einwegkunststofffonds levy (see below).

Distributor or wholesaler

According to the ZSVR, a German manufacturer, importer or wholesaler that is the first to make unbranded service packaging available in the German supply chain is itself the producer and licenses it; this is no longer "pre-licensing" on the restaurant's behalf. A restaurant buying unbranded packaging from such a German supplier should, as a distributor (Art. 19(2) PPWR), check that the supplier has met those duties. If the wholesaler supplies packaging bearing the restaurant's brand, the restaurant is the producer.

Foreign manufacturer

A foreign company without a German establishment that supplies end users in Germany directly must appoint a Bevollmächtigter (authorised representative) established in Germany to fulfil its EPR duties (§ 5 VerpackDG, implementing Article 45 PPWR). For service packaging, a manufacturer outside Germany, for example in Türkiye, generally cannot take over licensing for a German restaurant chain: packaging printed with the buyer's brand makes the buyer producer, and a German business importing unbranded service packaging is usually the producer itself. The only remaining pre-licensing route (§ 7(2) VerpackDG) applies where no PPWR manufacturer is established in Germany, which in practice means a foreign Vorvertreiber; the ZSVR does not say whether such a supplier then also needs a Bevollmächtigter, so confirm the set-up with the ZSVR and your dual system. In most supply chains, the German brand owner, importer or wholesaler licenses, and the foreign manufacturer supplies the material and weight data per item that licensing requires.

How does pre-licensing of service packaging work?

Under § 7(2) VerpackDG, only a producer of service packaging that counts as manufacturer under Article 21 PPWR (because it modifies the packaging) can require its upstream distributors (Vorvertreiber) to take over system participation for the unfilled service packaging they supply. The ZSVR says this applies only where no PPWR manufacturer is established in Germany, leaving two cases: a micro-enterprise that orders neutral service packaging from outside the EU and then adds its own brand or otherwise modifies it (for example with a sticker), and any other business that orders neutral service packaging from outside the EU or from another EU Member State and then brands or modifies it. It is not available for packaging ordered with your own name, logo or brand, whether ordered in Germany or abroad. Where it applies, the registration, reporting and completeness-declaration duties (§§ 6, 9 and 10) pass to the Vorvertreiber, which cannot pass them on further; the original producer must still register in LUCID and can ask for confirmation of the system participation.

Points to check:

• Which items are covered (cups, lids, bags, wraps, boxes) and for which quantities.
• Whether your case is one of the two remaining § 7(2) cases at all; if you previously declared service packaging as pre-licensed ("vorbeteiligt") in LUCID, the ZSVR says this entry needs updating.
• How the confirmation is documented on invoices or in a separate statement.
• Whether the packaging carries your name, logo or brand, because that makes you the producer and rules out pre-licensing.

What is the Mehrwegangebotspflicht (Mehrwegpflicht)?

Since 1 January 2023, under the reuse duty usually called the Mehrwegpflicht, takeaway outlets in Germany that fill single-use plastic food packaging or single-use cups of any material must also offer a reusable alternative at no higher price. Small outlets with no more than five employees and no more than 80 m² of sales area are exempt but must fill customers' own containers on request. Under the VerpackDG (BGBl. 2026 I Nr. 207, in force 12 August 2026) the duty is in § 60 and the small-outlet rule in § 61 (formerly §§ 33 and 34 VerpackG). Employees are counted across the business as a whole (part-time staff pro rata), and for deliveries storage and dispatch areas count as sales area, so branches of a chain generally do not qualify.

For buyers this means:

• Paper cups are in scope regardless of lining, because the duty covers single-use cups of any material.
• Paper-based food boxes are in scope only if they count as single-use plastic food packaging; a PE-lined or plastic-coated box may count.
• From 12 February 2027 and 12 February 2028, the PPWR adds EU-wide bring-your-own and reusable-offer duties (Articles 32 and 33). See the PPWR guide.

What does the Einwegkunststofffonds levy cost?

Germany's single-use plastic fund (Einwegkunststofffondsgesetz) requires producers of certain single-use plastic products to register on the DIVID platform (since 1 January 2024) and pay an annual levy per kilogram, first charged in 2025 on 2024 quantities. The levy is paid by whoever first places the products on the German market, usually the importer.

Paper products with a plastic lining or coating can fall within the single-use plastic product categories, following the SUP Directive approach. A PE-lined paper cup may therefore be a levy-relevant beverage cup. There is no minimum plastic content, and the Umweltbundesamt's audit guidelines (Prüfleitlinien, February 2025) require the whole single-use plastic product to be weighed, not only its plastic component, so the levy on a PE-lined cup is calculated on its full weight including the paper. Since 3 November 2025, under a UBA administrative rule, food containers and packets holding more than 500 g of food are treated as not intended for immediate consumption and fall outside those two categories. Confirm classification with DIVID guidance or your adviser, and ask your supplier for the total weight per item.

How does packaging compliance work in Austria?

Austria regulates packaging through the Verpackungsverordnung 2014, amended in 2023. Packaging placed on the Austrian market must be licensed with a collection and recovery system such as ARA or Reclay. National implementation of the PPWR's EPR side is pending as of October 2026, so the existing system continues; the BMLUK published a fact sheet in June 2026.

Who is responsible in Austria

• Austrian brand owner or chain: typically licenses the packaging it places on the market with a collection system, or buys packaging licensed upstream where the supplier offers this.
• Importer: the Austrian importer is usually the party placing the packaging on the Austrian market and licensing it.
• Distributor: may license on behalf of its restaurant customers; confirm in writing.
• Service packaging: the primary obligation sits with the manufacturer or importer of the service packaging established in Austria (§ 13g(1) no. 1 AWG 2002), so restaurants buying from an Austrian supplier normally receive licensed packaging; a restaurant that imports service packaging itself becomes the importer.
• Foreign distance sellers: for packaging placed on the market from 1 January 2023, foreign distance sellers supplying private end consumers in Austria must appoint an Austrian Bevollmächtigter (§ 16b Verpackungsverordnung 2014).
• Manufacturers in other EU Member States supplying Austrian businesses: may voluntarily appoint a Bevollmächtigter (§ 16a Verpackungsverordnung 2014). This option is limited to companies established in the EU; suppliers outside the EU, for example in Türkiye, rely on their Austrian importer or customer to license.

The PPWR itself, including the PFAS limits from 12 August 2026 and the reuse duties from 2027 and 2028, applies directly in Austria as in every Member State.

Germany and Austria compared

Timeline

Documents to request from your packaging manufacturer

• Material composition and weight per item and per component (paper, plastic coating, window film, handle), for LUCID/dual system or collection-system reporting.
• Total weight per item for single-use plastic products, for Einwegkunststofffonds reporting (the levy is calculated on the whole product's weight, not only the plastic share).
• Confirmation of whether the supplier, its German or Austrian distributor, or you will license the packaging; written pre-licensing confirmation where applicable.
• PPWR EU Declaration of Conformity or the technical data you need as manufacturer of your branded packaging.
• Food-contact Declaration of Compliance and, from 2027, ink supplier confirmation of conformity with the German Printing Ink Ordinance (see food-contact packaging compliance).
• PFAS statement and test data (see PFAS-free food packaging).

When you source from an exporter outside Germany and Austria, such as 9 Packaging in Istanbul, agree at quotation and technical review which material and weight data per item will accompany each delivery, so that you or your importer can register and license without chasing figures later.

What this means for foodservice and e-commerce packaging

• Paper cups: licensing, the Einwegkunststofffonds levy if PE-lined, the reuse duty and SUP marking. See custom printed paper cups and paper cup rules in Europe and the UK.
• Takeaway boxes and food containers: licensing; plastic-lined versions may trigger the reuse duty and levy. See custom printed takeaway food boxes and custom printed paper food containers.
• Takeaway bags: licensed as service packaging; paper bags are outside the plastic levy. See custom printed takeaway bags.
• E-commerce shipping boxes: sales packaging that reaches private consumers in Germany requires LUCID registration and system participation by the online seller; foreign online sellers need a Bevollmächtigter.

Terminology by market

German buyers and authorities use Verpackungsgesetz or VerpackG (now VerpackDG), Systembeteiligung (system participation), Serviceverpackungen (service packaging) and Vorlizenzierung (pre-licensing). In Austria, a carrier bag is commonly a Sackerl or Tragtasche, and a cone-shaped paper bag a Stanitzel; the licensing bodies are referred to as Sammel- und Verwertungssysteme (collection and recovery systems).

Next step: map who registers what

Before your next order, list each packaging item with its material, weight, plastic content and whether it is branded, then decide for Germany and Austria separately who is the producer, who licenses and whether any pre-licensing applies. Share that list with your supplier so the right data comes with each delivery. To specify new items with this information built in, use our packaging RFQ guide or send your requirements via our contact page.

Related reading

• Packaging Compliance in the Netherlands: Verpact, Waste Management Fee and Single-Use Cup Rules