With the EU Packaging and Packaging Waste Regulation (PPWR), the legal requirements for companies placing packaged products on the market for the first time are changing. For example, when you distribute brand-owned products or imported wares in Germany without a domestic intermediary, you are legally considered a ‘producer’ and are obliged to license all packaging with a dual system and register it with the Central Agency for Packaging Registers (ZSVR). To ensure compliance with legal requirements, it is important that you record your packaging data accurately and transparently. Instead of rough estimates or depending on data from upstream suppliers, we recommend reliable weight data for each material type, supplemented in the future by information on recyclability and the use of recycled materials.
In practical terms, this means for you: You must check whether you are considered the first distributor of your product packaging, systematically record your packaging volumes (e.g., via weighing, valid calculations or reliable supplier data), license these with a dual system and report them to the LUCID packaging register. At the same time, it is becoming increasingly important to document this data internally in such a way that it can be verified at any time in case of doubt. These obligations already exist today, however, the upcoming EU requirements significantly increase the pressure and make a structured, data-based approach mandatory.
The ZSVR states on its website that there will be no transition period; failure to promptly adjust system participation for packaged products will result in a sales ban effective 12 August 2026.
Beyond the sales ban, the legal situation from 12 August 2026 may also result in fines up to 200,000 euros and competition law warning notices from competitors. Monitoring is conducted by the ZSVR in collaboration with the enforcement authorities of the respective German federal states. With public registers, systematic data comparisons, and greater market transparency, violations are increasingly likely to be detected – making inaction an economic risk.
The good news: You now have the opportunity to plan ahead, adjust your processes, and maintain transparency before stricter requirements come into effect.
trade-e-bility GmbH develops practical approaches for you to implement these requirements in compliance with the law. Affected companies may contact us here to be given priority access to the new solution!
Do you have questions about the systematic recording of packaging? trade-e-bility will be happy to provide you with a suitable quote! Simply call 040/750687-300 or send us an email.
EU Packaging Regulation Workshops: Secure your place now!
Starting with the first session on role clarification on 28 May, we will focus on Article 3 of the PPWR, with particular attention to the definitions, distinctions and responsibilities of “manufacturers” and “producers”.
