Packaging under your name
You are manufacturer and producer, even if a factory in India or China makes and fills the packaging for you.
Germany · France · EU packaging EPR
Packaging EPR: registered before the first sale.
Extended producer responsibility (EPR) makes the business that first puts packaging on a national market register and pay for its collection and recycling. In Germany, the Packaging Law Implementation Act (VerpackDG) replaced the Packaging Act on 12 August 2026; in France, producers join an approved eco-organisme, show their unique identifier (IDU) and print the Triman logo on household packaging.
- 12 Aug 2026
- VerpackDG replaced VerpackG
- 15 May
- German declaration of completeness
- IDU
- French EPR number on your terms of sale
Status · checked 28 Sep 2026 VerpackDG since 12 Aug 2026
- France: IDU and marketplace duties
- France: representative for producers abroad
- Germany: VerpackDG and PPWR apply
- 28 Sep 2026
- Germany: declaration of completeness for 2026
- Germany: transitional end for producers
The short answer
What you need to know.
Checked against official sources on 28 September 2026.
- 01
EPR sits with the producer: the first company to make packaging available in a country, or a foreign company that ships directly to end users there. If packaging carries your name or brand, you are both manufacturer and producer.
- 02
Germany: since 12 August 2026 the PPWR and the VerpackDG replace the VerpackG. Register in LUCID, sign a system participation agreement for packaging subject to system participation (shipment packaging always is), and report volumes.
- 03
Foreign sellers without a German branch that sell directly to end users must appoint an authorised representative from 12 August 2026. LUCID registration stays your own duty. Declarations of completeness are due by 15 May above 80 t glass, 50 t paper or 30 t lightweight packaging.
- 04
France: join an approved eco-organisme for household packaging (Citeo, Adelphe or Léko), show your ADEME IDU in your terms of sale (since 1 January 2022), and print the Triman logo with sorting information on household packaging.
- 05
Since Law No 2026-602 of 8 July 2026, anyone not established in France who is subject to EPR appoints a representative established in France by written mandate.
Who it applies to
Who counts as the producer?
The PPWR split packaging roles in two: the manufacturer answers for conformity, the producer for EPR in each country where packaging becomes waste.
First in the domestic chain
Unbranded packaging: the first company to make it available in the country is the producer there.
Shipping direct from abroad
Selling from outside the country straight to end users makes you the producer, with a representative required in Germany and France.
Platforms and fulfilment
In France, platforms facilitating distance sales have EPR duties; in Germany, fulfilment and shipment packaging questions follow ZSVR guidance.
Key dates
Every date, with its source.
Only dates set in law or official publications. Anything still proposed is marked as proposed.
-
France: IDU and marketplace duties
Producers show their unique identifier; platforms facilitating distance sales provide or contribute to EPR for products they help sell.
-
France: representative for producers abroad
Law No 2026-602 inserts Article L. 541-10-9-1: written mandate to a representative established in France.
-
Germany: VerpackDG and PPWR apply
VerpackG replaced. Registration, system participation and data reporting continue; mandatory authorised representative for producers abroad selling directly to end users.
- Today · 28 September 2026
-
Germany: declaration of completeness for 2026
Audited by a ZSVR-registered auditor, filed in LUCID. For reference year 2026: VerpackDG form, VerpackG content.
-
Germany: transitional end for other PROs
For packaging not subject to system participation, other producer responsibility organisations need ZSVR authorisation after this date.
-
Germany: transitional end for producers
Producers handling packaging not subject to system participation themselves need ZSVR authorisation after this date.
-
EU harmonised sorting labels
PPWR labels showing material composition, or 24 months after the implementing acts if later.
Side by side
Germany and France, compared.
The same principle, different mechanics. The PPWR adds an EU layer: producer registers in every Member State (Art. 44) and an authorised representative where you are not established (Art. 45).
| Germany | France | |
|---|---|---|
| Law | VerpackDG with the PPWR, since 12 August 2026 | Environmental Code (AGEC law provisions) with the PPWR |
| Register | LUCID Packaging Register (ZSVR), before placing packaging on the market | SYDEREP (ADEME), via your eco-organisme; one IDU per scheme |
| Pay for recycling | System participation agreement with a system operator | Membership of an approved eco-organisme (Citeo, Adelphe, Léko) or an approved individual system |
| Report | Volumes to LUCID and your system; declaration of completeness by 15 May above thresholds | Annual data to your eco-organisme, which declares to ADEME |
| Selling from abroad | Authorised representative required for direct sales to end users; LUCID registration stays with you | Representative established in France, by written mandate (L. 541-10-9-1) |
| On-pack marks | PPWR marks; EU harmonised labels from 2028 | Triman logo with sorting information on household packaging (except glass beverage packaging) |
What you need from suppliers
The packaging data EPR reports run on.
EPR fees and reports are calculated by material and weight. That data starts at the factory.
- Component weights per SKUEvery packaging part weighed: box, inserts, poly bag, labels, tape, fillers and shipper carton.
- Material per componentPaper and board, plastic type, metal, glass or composite, so each gram lands in the right fraction.
- Artwork with required marksTriman and sorting information for French household packaging; importer name and address under the PPWR.
- Units per shipmentQuantities shipped per market, to turn weights per unit into tonnes per year.
- Change noticesAdvance notice of any change in packaging material or weight that alters your reports.
- Supplier information (PPWR Art. 16)Documentation from the packaging supplier to support your manufacturer duties.
How SourceSquid helps
From your product list to an audit-ready file.
Our teams in Bengaluru and Ningbo collect the evidence at the factory, in the supplier’s own language, while production runs.
- 01
Packaging weigh-in
Our inspectors weigh and photograph each packaging component at the factory during inspection.
You receivePackaging weight sheet - 02
Role check per country
Manufacturer and producer roles mapped for each market you ship to, including direct-to-consumer sales.
You receiveEPR role map - 03
Artwork review
Triman, sorting information and importer details checked on artwork before print.
You receiveArtwork approval notes - 04
Reporting data
Tonnes by material and country, ready for LUCID, your system operator or your eco-organisme.
You receiveEPR volume report data - 05
Representative coordination
We work with your chosen authorised representative so they receive complete, consistent data.
You receiveData hand-over pack - 06
Watch and update
National rules tracked as Member States align with the PPWR.
You receiveCompliance Radar updates
Sources
Official texts behind this page
Checked on 28 September 2026. This page explains the rules in plain English; for a view on your own products, ask our team or your legal adviser.
- ZSVR: PPWR and VerpackDG, what changed on 12 August 2026Roles; authorised representative; authorisation transitional dates
- ZSVR: declaration of completenessThresholds 80 t / 50 t / 30 t; deadline 15 May
- ZSVR: mail order companies and online retailers under the PPWRShipment packaging always subject to system participation
- ADEME: unique identifier (IDU) for EPR schemesL. 541-10-13; R. 541-173
- French Ministry for Ecological Transition: general framework for EPR schemesL. 541-10-9 marketplaces; Triman
- French Ministry for Ecological Transition: Triman and sorting information FAQL. 541-9-3; R. 541-12-21
- Loi n° 2026-602 du 8 juillet 2026 (AIDA, INERIS)Art. 5: new Article L. 541-10-9-1
- Regulation (EU) 2025/40 (PPWR)Arts. 44, 45
Related compliance guides
Rules that often travel together.
EU · packagingPPWRPackaging and Packaging Waste Regulation (EU) 2025/40: conformity, substances, labels and recyclability.→EU · chemicalsREACHSVHC communication under Article 33, ECHA notifications and Annex XVII restrictions.→Weekly updatesCompliance RadarRecent and upcoming rule changes, dated and sourced.→
Packaging EPR questions
Straight answers.
Dates checked against official sources. We update this page when the rules move.
anirudh@sourcesquid.coWhat changed for packaging EPR in Germany on 12 August 2026?
The EU Packaging and Packaging Waste Regulation and the German Packaging Law Implementation Act (VerpackDG) replaced the Packaging Act (VerpackG). Registration in the LUCID Packaging Register, system participation and data reporting remain. What changed is who holds these duties, following the PPWR’s manufacturer and producer roles, and producers based abroad that sell directly to end users in Germany must now appoint an authorised representative.
Can an authorised representative register my company in LUCID?
No. According to the Zentrale Stelle Verpackungsregister, the authorised representative takes on extended producer responsibility obligations in Germany on the producer’s behalf, with one exception: registration in the LUCID Packaging Register remains the obligated company’s own responsibility. The representative must be named in LUCID at the initial registration.
Who must file a declaration of completeness in Germany?
Companies whose packaging placed on the German market in the previous calendar year reached at least one threshold: 80 tonnes of glass, 50 tonnes of paper, paperboard and cardboard, or 30 tonnes of lightweight packaging (ferrous metals, aluminium, plastics, beverage cartons and other composites). The audited declaration is filed in LUCID by 15 May for the previous year.
What is the French EPR unique identifier (IDU)?
The IDU is issued by ADEME as proof that a producer is registered for an EPR scheme in the SYDEREP tool, one per scheme. Since 1 January 2022, producers show it in their general terms and conditions of sale or, failing that, in another contractual document given to the buyer, and websites show it too (Environmental Code L. 541-10-13 and R. 541-173).
Do foreign sellers need a representative in France for packaging EPR?
Yes. Law No 2026-602 of 8 July 2026 inserted Article L. 541-10-9-1 into the French Environmental Code: a person not established in France that is subject to extended producer responsibility appoints, by written mandate, a natural or legal person established in France to ensure its obligations are met. Online marketplaces facilitating distance sales have had their own EPR duties since 1 January 2022.
Start here
Accurate packaging data for every EPR report.
Send us your SKUs and the countries you sell in. We return your EPR roles by country and the packaging data each report needs.