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23 October 2025Mitigating the impact of Germany’s new Packaging Act (VerpackG) on Your EU supply chain
In an era defined by sustainability, environmental accountability, and tightening legal frameworks, businesses operating within the European Union can no longer treat packaging compliance as an afterthought. Regulations are evolving fast and packaging, once a purely functional aspect of distribution, is now a regulated touchpoint of environmental responsibility.
The European Union’s push toward a circular economy has transformed packaging laws into one of the most closely monitored areas of trade and logistics. Companies that design, produce, import, or distribute packaged goods across borders must navigate a web of national and EU-level rules designed to reduce waste, increase recyclability, and improve transparency across the supply chain.
Germany, as the EU’s largest market and a frontrunner in environmental regulation, sits at the heart of this transformation. The German Packaging Act (VerpackG) imposes strict responsibilities on all businesses placing packaging on the German market - from manufacturers and importers to online retailers and fulfillment service providers. At the same time, the new EU Packaging and Packaging Waste Regulation (PPWR) will soon unify and expand these requirements across the entire bloc, raising the compliance bar for everyone involved in European trade.
For businesses trading within or supplying to Germany, understanding and mitigating the impact of these regulatory shifts is not just a compliance issue - it’s a strategic necessity. The right logistics and compliance strategy can mean the difference between seamless market access and costly disruption.
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European landscape: packaging regulation and the drive to circularity
Across the European Union, packaging and packaging waste have been regulated for several decades, with the original directive being Packaging and Packaging Waste Directive (94/62/EC) (PPWD). Under this framework, Member States set recovery and recycling targets and required packaging to meet essential requirements for reuse or recyclability.
However, the regulatory tide is shifting from directive to regulation - with the power to directly shape national law and harmonise requirements across the internal market. The PPWR (Packaging and Packaging Waste Regulation) entered into force on 11 February 2025 and will apply generally as of August 2026. The regulation aims to ensure that all packaging placed on the EU market is recyclable in an economically viable way by 2030, to increase recycled content, reduce virgin material use, and strengthen a circular-economy transition.
For supply-chain operators - those manufacturing, importing, distributing or fulfilling goods destined for EU consumers - the implications are real: packaging design, material choices, data reporting, and cross-border logistics will be affected. In particular, for companies shipping into Germany, adaptation must begin now.
Germany as a compliance hotspot: understanding the VerpackG
Germany, Europe’s largest economy and a major consumer market, has embedded a robust packaging-compliance regime via its Packaging Act (VerpackG) which entered into force on 1 January 2019. Key features of the Act:
- it enshrines the principle of extended producer responsibility (EPR) for packaging: companies placing packaged goods for private final consumption on the German market must take responsibility for the disposal and recycling of that packaging;
- obligations apply not only to domestic German manufacturers, but also to importers, e-commerce businesses, and any entity that places packaging into circulation, including shipping and service packaging materials;
- all obligated entities must register in the national packaging register called LUCID, maintained by the Zentrale Stelle Verpackungsregister (ZSVR);
- licence fees must be paid by obligated companies via a “dual system” for recycling (i.e. participating in an approved scheme);
- reports of quantities placed on the German market must be submitted; failure to comply may trigger market access restrictions (especially relevant for marketplace sellers).
Why the German market is a focal point
Several factors make Germany especially important in the EU supply-chain compliance landscape:
- market size and e-commerce penetration: with one of the largest online-retail sectors in Europe, shipments destined for German consumers are often high-volume and cross-border;
- tight enforcement and marketplace responsibilities: from 1 July 2022, major marketplaces such as eBay started verifying compliance of sellers shipping to Germany under VerpackG and blocking non-compliant offers;
- advanced national infrastructure and data transparency: Germany’s ZSVR provides a publicly searchable register and continues to raise minimum standards for recycling-friendly packaging design.
For any business whose packaging-to-consumer chain includes Germany, non-compliance is no longer a minor risk - it may lead to restricted market access, reputational cost and financial penalty.
New developments and emerging risks for supply chains
While the Packaging Act sets out current obligations, firms must also prepare for evolving regulatory demands:
- amendments to VerpackG: Germany continues to refine its law; one summary notes the law underwent changes in 2021–2022 to tighten obligations, especially for foreign sellers and e-commerce;
- upcoming PPWR obligations: with the PPWR set for August 2026 general application, all EU Member States (including Germany) must enforce new rules on recyclability, minimum recycled content, labelling, reuse systems, prohibition of deceptive packaging, compostability standards and more;
- cross-border import & e-fulfillment complexities: for companies outsourcing storage, fulfillment or shipping to Germany (or broader EU markets), questions around “who is the producer” and “who bears compliance” are complex; notably, if a foreign company places goods into Germany's sales-packaging chain, it may be obligated under VerpackG regardless of domicile.
Marketplace ecosystem risk: with major marketplaces enforcing verification of EPR registration and licensing documentation (e.g. LUCID number) for sellers accessing German consumers, supply chains that don’t plug into compliance may face listing removal or blocked shipments.
Practical steps for supply-chain mitigation
Given this environment, what can businesses do today to reduce risk, ensure compliance, and seize competitive advantage? Below are practical, actionable steps aligned to the German market and EU-wide context.
Map your packaging flows and responsibilities
Start by auditing your packaging chain:
- Identify all packaging types that end up with German end-consumers (including product packaging, secondary/transport/shipping packaging, service packaging). Under VerpackG, all materials count (plastic, paper/cardboard, glass, metal, composites, wood, etc.).
- Determine which party in your supply chain is the “initial distributor”, i.e. the first entity that places the packaged goods into circulation in Germany. That party is typically responsible for registration and licensing under the Pflicht (EPR) regime.
- If you use third-party fulfillment or cross-border logistics (e.g. you ship to a German warehouse and onward to consumers), clarify whether your logistics provider or you retain compliance liability.
- Review whether you (or a partner) are already registered with LUCID (German register), whether a dual-system licence has been obtained, and whether the volumes and materials have been reported.
Register & license now if German shipments occur
If you are placing packaged goods (directly or via fulfillment services) into the German market:
- Register on the LUCID Packaging Register via the ZSVR.
- Enter into a contract with a dual-system provider in Germany to licence your packaging volumes and materials (system participation).
- Submit quantity declarations of the packaging placed on the German market and report to ZSVR as required.
- Ensure you obtain and maintain your EPR number (registration number) and are prepared to supply proof of compliance to marketplaces, customers or auditors.
Align packaging design and materials for sustainability and regulatory readiness
While current obligations focus on registration/licensing, the upcoming PPWR and evolving German minimum standards call for proactive redesign:
- Review whether your packaging is designed for high-quality recycling, reuse or recovery (in line with “design for recyclability” principles).
- Where possible, reduce packaging volumes, improve recyclability (monomaterials rather than complex composites), clearly label materials and consider recycled content or reusable packaging structures.
- Anticipate future labelling and recyclability requirements: the PPWR sets deadlines for minimum recycled content (from 2030), labelling obligations (from 2026) and reuse/return systems (from 2030).
- Engage your packaging suppliers early to align their sourcing and design with these regulatory requirements to prevent costly redesigns or non-compliance later.
Integrate compliance in logistics & fulfillment workflows
Logistics and fulfillment providers play an increasingly important role in supply-chain compliance. For companies selling online, the domestic German fulfillment and warehousing footprint matters:
- If you outsource to a German fulfillment provider or store goods in Germany before shipping to German consumers, ensure the fulfillment partner is aware of VerpackG obligations and can assist with documentation, registration and supply-chain transparency.
- Assess the entire EU logistics chain, including cross-border inbound freight (from Asia or elsewhere), warehousing (in Germany or EU hubs), returns handling and outbound delivery to German consumers. Each step may influence who is responsible under VerpackG or future PPWR.
- Use providers who integrate compliance support (registration, data reporting, licence checks) with logistics operations.
Monitor enforcement and marketplace risk
- If you sell via German marketplaces or cross-border to German consumers, be prepared for regulatory due diligence: marketplaces may request your German EPR registration number, proof of licence with a dual system, packaging-volume data and may suspend listings for non-compliance.
- Stay alert to audits, public register checks via ZSVR, and increased enforcement. Non-compliance may lead to monetary penalties, restricted market access, reputational damage or heightened scrutiny.
- Furthermore, embed compliance into your internal processes: assign clear ownership (who is responsible for packaging data, registration updates, licence renewals), maintain accurate records and document your packaging strategy.
Mitigation benefits beyond compliance
Addressing packaging-compliance requirements offers advantages beyond “just avoiding fines.” Companies that proactively adapt packaging and supply-chain strategies can achieve:
- operational resilience: by embedding regulatory-driven processes now, organisations reduce risk of last-minute redesigns or supply-chain disruptions when the PPWR and other regulations come into full effect;
- cost optimisation: Early design for recyclability often leads to lighter, simpler packaging - reducing materials, transport weight and waste-management fees (especially under EPR schemes);
- market competitiveness: in Germany and across the EU, sustainability credentials matter; demonstrating compliance and recyclable packaging may support better brand perception, retailer partnerships and e-commerce market access;
- supply-chain transparency: a deeper mapping of packaging flows, registered obligations and logistics nodes enhances overall supply-chain visibility - helping with returns management, fulfillment flexibility and cross-border optimisation.
- Future-proofing: With PPWR’s looming deadlines, companies that start now are better positioned to meet stricter requirements (minimum recycled content, reuse systems, labelling obligations) by 2030 and beyond.
Packaging-regulation landscape in Europe
In summary, the packaging-regulation landscape in Europe is evolving rapidly, and compliant supply chains need to keep pace. The German Packaging Act (VerpackG) already imposes extensive obligations for businesses placing packaged goods into the German market - from registration, licensing, data-reporting to design standards. Moreover, the upcoming EU Packaging and Packaging Waste Regulation (PPWR) will raise the bar further across the EU market from 2026 onwards.
To mitigate the impact of these changes, companies should map packaging flows, register and licence where required, redesign packaging for recyclability, integrate compliance into logistics and fulfillment operations, and monitor enforcement risk, especially in Germany.
Conclusion
If your business is seeking a partner to help manage logistics, warehousing, fulfillment and customs clearance in Germany and the wider EU - while aligning with packaging-compliance requirements - feel free to explore working with FLEX. Logistik. Our expertise in e-commerce logistics across major European hubs positions them well to help you navigate both operational and regulatory complexity.
Ready to take the next step? Contact FLEX. today and support your EU supply-chain, logistics fulfillment and packaging-compliance journey.
