What Companies Need to Do Now

Since the German Packaging Act Implementation Act (VerpackDG) and the EU Packaging Regulation (PPWR) took effect on August 12, 2026, the new core requirements are already binding. Those who act quickly now and fulfill all obligations will save time and money and avoid severe penalties.

Step by step.

The 5 Steps to Packaging Compliance

This sequence has proven effective in practice. Each step builds on the previous one—and every step you take now will save you effort later.

 

Systematically Assess the Impact

Before you do anything else: Determine whether and to what extent your company is affected. The key question is whether you are placing packaging or packaged products on the market in Germany for the first time on a commercial basis—as a producer, manufacturer, filler, importer, or distributor.

Proceed by packaging category: Which packaging is intended for private customers (B2C)? Which is intended for businesses (B2B)? Which types are newly covered by the PPWR? A structured inventory serves as the foundation for all further steps.

Tip

Take advantage of our free initial consultation for a packaging compliance check—even if you just need a general overview.

Comprehensively Track Packaging Flows

Create a complete overview of all packaging or packaged products that your company places on the market: by material (plastic, paper, glass, metal, composite), by category (retail packaging, transport packaging, service packaging), and by quantity (annual quantities in kilograms or metric tons).
Specifically examine which packaging formats could be affected by the bans under Annex V of the PPWR. Redesigning these formats often requires a lead time of 12–18 months.

Tip

Include supply chain and purchasing data—many packaging quantities are already recorded in ordering systems and simply need to be categorized.

Clearly Define Internal Responsibilities

Packaging compliance is not an isolated issue—it affects procurement, logistics, production, legal affairs, sustainability, and management all at once. Without clear internal accountability, nothing will get done.
Appoint a responsible individual or a small team with decision-making authority and sufficient time. In medium-sized companies, this role is often filled by the sustainability officer or the environmental manager—in smaller companies, it is often handled directly by management.

Tip

A kick-off workshop with all relevant departments—often 90 minutes long—saves months of back-and-forth via email.

Organize System Participation and Registration

Once your packaging streams and responsibilities are clear: Register with the LUCID Packaging Registry of the Central Office (ZSVR) and, for your B2C packaging, you must join a dual system (mandatory—required by law). For B2C packaging, this is a dual system; for your packaging in the industrial/commercial sector (B2B), we recommend participating in the RIGK and/or RIGK-G-SYSTEM.

Important: Registration must take place before the packaging is first placed on the market. Failure to register on time may constitute an administrative offense.

Tip

We recommend that you transfer the extensive, complex obligations imposed on manufacturers—regarding packaging take-back—to the authorized collective manufacturer organization RIGK.

By participating in the RIGK and/or RIGK-G-SYSTEM, you will be in full compliance with German law!

Establish Documentation and Reporting

The final—and often underestimated—step: Establish the processes that will keep you compliant in the long term. This includes annual volume reports, proof of recovery, recyclability certificates (new as of 2026), and the retention of all supporting documents.

Those who have joined the RIGK take-back systems are exempt from these verification and documentation requirements. For everyone else, we recommend maintaining a simple internal documentation register that is immediately available during government inspections.

Tip

Plan for digital reporting from the very beginning—by 2027 at the latest, government interfaces for digital volume reporting will be the standard.

Internal Organization.

Which departments must be included?

Packaging compliance is a cross-functional issue. No single department can address it on its own—and if it isn’t coordinated, gaps will arise.

 

Purchasing

Manages packaging procurement and is familiar with materials and quantities. Must evaluate suppliers for recyclability and recycled content and incorporate these requirements into purchasing contracts.

Key Role: Data Provider

Logistics & Production

Has knowledge of actual packaging flows and volumes. Responsible for the operational implementation of take-back and disposal processes, volume measurement, and supply chain documentation.

Key Role: Quantity Tracking

Legal & Compliance

Assesses legal obligations, coordinates registration and system participation, monitors deadlines, and ensures that all reporting and documentation requirements are met.

Key Role: Legal Certainty

Sustainability / ESG

Responsible for recyclability testing, labeling requirements, and the use of recycled materials. Coordinates design-for-recycling initiatives and ensures compliance with greenwashing regulations for sustainability communications.

Key Role: Recyclability

IT & Data

Ensures that inventory reports, reporting systems, and documentation can be digitally mapped. This is relevant for future integration with LUCID and regulatory interfaces.

Key Role: Reporting Systems

Executive Management

Must prioritize compliance as a strategic priority, approve the budget, and make decisions regarding packaging redesign, system selection, and partnerships. Ultimately bears responsibility to regulatory authorities.

Key Role: Decision-Making & Budget

Recommendation

Appoint a single person to serve as the internal coordinator—ideally from the sustainability or packaging compliance department. This person will serve as the point of contact for RIGK and all internal departments.

Is your company affected? Learn more

Quick Check.

How do I determine whether I am affected? of my company?

The impact assessment follows a clear logic. Answer these questions in order:

 

Who is the manufacturer/producer?

Does your company place packaging or packaged products on the market in Germany for the first time—through manufacturing, filling, importing, or distribution?

Which packaging categories are affected? 

  • Packaging subject to mandatory participation in the system
  • Packaging not subject to the system
  • Retail packaging
  • Service packaging
  • Outer packaging 
  • Transport packaging
  • Primary production packaging
  • Packaging for e-commerce
  • Disposable packaging 
  • Reusable packaging

What materials are used?

Plastic, paper/cardboard, glass, aluminum, steel, composite materials? Different recycling rates and requirements for the use of recycled materials apply depending on the material.


Are there any prohibited formats?

Check your packaging against Annex V of the PPWR—certain single-use formats will be banned starting in 2030. A redesign requires lead time.


Are you already registered?

If you are already registered in the LUCID system: Does your existing registration cover all the new packaging categories added by the Packaging Act (VerpackDG)?

Not sure about any of these points?

A structured initial consultation with RIGK will provide clarity on the full extent of your situation.

Request a Packaging Compliance Check

Common Mistakes.

What Companies Should Consider When Getting the preparation wrong

We see these mistakes time and time again—and they can all be avoided.

 

Assumption that B2B is not affected.

Commercial, industrial, and agricultural packaging are now subject to take-back obligations. Many B2B companies significantly underestimate the need for action.

Treat Packaging Compliance as a Separate Topic

If only one department is responsible, blind spots will arise. Packaging compliance affects at least purchasing, logistics, legal, and sustainability.

Do not allocate a budget for packaging redesign.

Single-use packaging formats that will be banned starting in 2030 must be redesigned in a timely manner. That takes time and money—neither of which can be found at the last minute.

Ignoring greenwashing risks.

Claims such as “recyclable” or “sustainable” on packaging are now subject to stricter requirements. Anyone who fails to verify these claims risks receiving a warning letter—regardless of whether they participate in the recycling system.

Schreibtisch mit Laptop, Aktenstapeln und Kalender – Dokumentation und Nachweise für die Verpackungs-Compliance

Ready to get started—but not sure where?

RIGK guides you from the initial impact assessment all the way to a comprehensive compliance solution. No-obligation, practical, and backed by over 30 years of experience.

Register for the next webinar.Start working with RIGK today.

FAQ: What's changing—what do I need to do?

The questions we hear most often during initial consultations.

Clarify things before it becomes mandatory

RIGK guides you from the initial classification all the way to a practical take-back solution—with no obligation, tailored to your industry, and focused on your specific needs.

  • No one-size-fits-all solutions or answers—we tailor our approach to your specific situation
  • Decades of experience with take-back in the B2B sector
  • Support even as legislation continues to change
  • PACKLIANCE provides support with declarations of conformity and the appointment of authorized representatives in other EU countries

* Note: The information provided on this landing page offers an initial overview of the European Packaging Regulation (PPWR) and the national implementing law in Germany, the Packaging Law Implementation Act (VerpackDG). It is intended to provide guidance on the key obligations, responsibilities, and the solutions offered by RIGK. The content is not exhaustive and does not replace an individual assessment of a specific case or legal advice.