How can we help you with Packaging compliance?

The foundation for complying with legal obligations is a careful analysis of one’s own situation. Companies should therefore first clarify the following:

• What role do we play in the supply chain?
• What types of packaging do we place on the market in Germany?
• What legal obligations arise from this?
• Do we organize the take-back ourselves or through a specialized organization?
• What documentation and processes must be established internally?

Those who answer these questions early on and structure their processes accordingly lay the foundation for legally compliant packaging management and reduce risks in day-to-day operations.

Importers, retailers, and companies not based in Germany may also be affected by the Packaging Act (VerpackungsDG). Anyone who imports packaged goods into Germany or makes them available here must carefully assess their own role under packaging law.

Key points include:

• Importers must ensure that the packaging complies with the law and that the required documentation is available
• Retailers may not make products available if there are obvious compliance issues
• As things stand, companies without a branch in Germany generally need an authorized representative
• A German VAT ID alone does not replace an actual place of business in Germany

An early compliance review is particularly important, especially in international supply chains.

Companies must document their packaging compliance obligations in a transparent manner. The specific documents required depend on the type of packaging, the company’s role, and its distribution model.

Typical supporting documents include, among others:

• Proof of registration
• Quantity and packaging data
• Evidence of take-back and recycling
• Documentation regarding the organization of compliance efforts
• Proof of financing
• Technical documentation and conformity documents, if applicable

It is important that these documents be complete, reliable, and readily available when needed.

In Germany, a dual system is responsible for packaging subject to mandatory participation in the system—that is, generally packaging generated by private end consumers.

An organization for producer responsibility, on the other hand, handles tasks related to other types of packaging, particularly packaging not subject to the dual system. This includes, for example, take-back, recycling, organization, and record-keeping for packaging from the industrial and commercial sectors.

This distinction is important because it results in different obligations and implementation approaches for companies.

Companies can also delegate their obligations regarding take-back, recycling, and organization to a specialized producer responsibility organization.

This can be particularly useful for industrial and commercial packaging as well as transport packaging, as it allows companies to comply with legal requirements efficiently and in a legally compliant manner. For companies, this means a significant reduction in the burden of organization, documentation, and record-keeping.

RIGK has been supporting companies for many years with take-back and recycling solutions for the industrial and commercial sectors and is preparing to provide practical guidance to customers even under the new Packaging Act (VerpackDG).

In principle, companies may continue to take back their own packaging. In the future, however, this will be subject to stricter requirements. Any company wishing to independently organize its own take-back, recycling, and documentation obligations must be able to demonstrate that its plan is legally sound, robust, and sustainable in the long term.

This includes, in particular:

• a legally compliant take-back system
• sufficient financial safeguards
• reliable evidence and documentation
• the required authorization as well as a financing agreement with the ZSVR
• a long-term, sustainable structure for nationwide implementation

Self-take-back is therefore no longer a simple, off-the-shelf solution, but rather requires careful preparation and robust processes.

The packaging supplier generally provides technical information, specifications, and documentation. However, legal responsibility does not depend solely on the manufacture of the packaging, but rather on the respective role in placing the product on the market.

Anyone who places packaged products on the market in Germany or the EU is responsible, depending on the circumstances, for ensuring that the packaging complies with legal requirements. Companies should therefore not rely solely on suppliers but should actively assess their own role and responsibilities.

Companies that place packaging on the market in Germany must comply with various legal obligations depending on the type of packaging and their role in the supply chain. These include, in particular:

• the take-back and recycling obligation
• registration in the ZSVR’s LUCID registry
• Information obligations toward customers
• Record-keeping and documentation obligations
• Financing obligations
• If applicable, a license if take-back is organized internally

Transparent and reliable documentation will become even more important in the future, particularly for B2B packaging and packaging not subject to mandatory participation in a recycling system.

RIGK is a shareholder in PACKLIANCE GmbH, a consulting firm that provides global support to producers and manufacturers of industrial and commercial packaging regarding their PPWR obligations.

PACKLIANCE can act as an authorized representative under Article 3(1)(19) of the PPWR and as an authorized representative for extended producer responsibility under Article 3(1)(20) of the PPWR.

We ensure a seamless transition and coordination between RIGK and PACKLIANCE.

Registration on the LUCID portal must formally be carried out by the company itself—it is a non-transferable obligation of the manufacturer or distributor. However, RIGK is happy to assist you with this. Note: The process is not complicated, and many of our customers confirm that registration can be completed in just a few minutes.

RIGK, for example, is a PRO that collectively assumes the obligations of extended producer responsibility (EPR), such as the take-back of empty packaging and its recycling.

Section 3(10) of the Packaging Act (VerpackDG
): An “other organization for producer responsibility” is an organization for producer responsibility established under private law as a legal entity or a partnership with legal capacity within the meaning of Article 3(1)(66) of Regulation (EU) 2025/40, which, upon authorization pursuant to § 22, collectively fulfills the extended producer responsibility obligations of the participating manufacturers for packaging not subject to mandatory system participation.

RIGK specializes in companies that place packaging from the commercial, industrial, or agricultural sectors—as well as packaged products in the B2B sector—onto the market: producers, manufacturers, fillers, importers, distributors, and processors from industry, commerce, and agriculture. Dual systems such as the Green Dot are responsible for pure B2C packaging generated by private consumers. In many cases, a company serves both private end consumers and industrial/commercial customers—RIGK advises on which system is appropriate for which type of packaging.

The cost of participating in the system depends on the type and quantity of packaging and packaged products placed on the market. RIGK will prepare a quote for you based on the information you provide and our licensing fees.

Foreign companies that deliver goods directly to private end consumers or businesses in Germany are affected. They are generally considered manufacturers in the German market and must therefore register and fulfill their EPR obligations. These obligations apply even if the company has no physical presence in Germany.