Authorisation for packaging not subject to system participation will be possible as from late summer/ autumn 2027

Going forward, producers of packaging that is not subject to system participation will require an authorisation to fulfil their extended producer responsibility obligations. Pursuant to Article 47 of the EU Packaging and Packaging Waste Regulation (PPWR), the Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR) will be responsible for this authorisation.

The new Verpackungsrecht-Durchführungsgesetz (German Packaging Law Implementation Act – VerpackDG) provides for automated, electronic implementation of the authorisation procedures. These obligations can either be fulfilled by the producers themselves or by any other producer responsibility organisation (oPRO).  

Heads-up

Legally valid authorisations can only be applied for on the ZSVR's electronic systems. Because we are not allowed to start planning and developing these systems before July 2026, we expect to be able to provide them in the summer (for organisations) and autumn (for producers) of 2027. This is covered by the transitional provisions in the VerpackDG.

Transitional provisions 

  • Producers of packaging that is not subject to system participation are covered by a transition period ending 31 December 2027. Up until then, producers will be allowed to make this packaging available on the German market without an authorisation pursuant to section 19 VerpackDG (draft bill). An authorisation by the ZSVR will be required as from 1 January 2028.

  • The transition period for other producer responsibility organisation is slightly shorter: organisations under private law that assume the duties of an oPRO are allowed to do so without an authorisation pursuant to section 22 VerpackDG (draft bill) until no later than 31 October 2027. An authorisation will be required as from 1 November 2027.