The PPWR is a regulation. The same rules, the same definitions, the same deadlines, in all 27 member states at once. That is the theory, and it holds.
What the PPWR does not harmonise is enforcement. Registration, supervision and levies remain national. That is why, as a Dutch company supplying to Germany, you run into two registers, two systems and two levies — while the substantive requirements for your packaging are identical. And on one point the difference is big enough to get a company into trouble: Germany has no threshold.
The differences at a glance
| Netherlands | Germany | |
|---|---|---|
| Registration | Verpact | LUCID, at the Stiftung ZSVR |
| Threshold for the fee | 50,000 kg of packaging per year | none |
| Dual system | not applicable | mandatory (BellandVision, Reclay, and others) |
| Deposit | at least €0.15 | €0.25 Einwegpfand (DPG), 0.1–3 litres |
| SUP levy | litter contribution via Verpact, no threshold | EWKFondsG via DIVID, declaration before 15 May |
| Reuse in hospitality | PPWR art. 29(5) from 12 August 2026 | Mehrwegangebotspflicht since 2023, above 80 m² and 5 FTE |
| Sanction for failing to register | enforcement by the ILT | sales ban and fines up to €200,000 |
The 50,000 kg threshold is not an exemption
In the Netherlands the rule is: if you place less than 50,000 kg of packaging on the market per year, you do not have to pay a waste-management fee to Verpact. Three things that often go wrong here:
- It is a total threshold across all materials combined — not 50,000 kg of plastic plus 50,000 kg of cardboard.
- Below the threshold the fee lapses, not the administration. You must still know and be able to demonstrate what you place on the market.
- The SUP contribution has no threshold. If you place single-use plastic packaging on the Dutch market, you pay it from the first kilo.
And above all: the threshold is an EPR threshold. It says nothing about the PPWR itself. The substance restrictions, the traceability obligation and the declaration of conformity apply to the smallest company too. See PPWR and SMEs.
In Germany it starts with a single shipment
The German VerpackG has no lower limit. Anyone who places packaging that ends up with a private end user on the market in Germany must:
- register in LUCID at the ZSVR before the first shipment
- sign up with a dual system and pay a licence fee based on material and weight
If you do not, a sales ban applies and you risk a fine of up to €200,000. Since 1 July 2022 this explicitly also applies to foreign webshops that supply German consumers directly. One pallet, one trial shipment, one German customer via your webshop: it makes no difference.
Not sure whether this applies to your packaging? The PPWR Check walks through your role, market and material in eight questions and shows per pillar what applies to you. Take the PPWR Check →
Manufacturer or producer — and why that matters here
The PPWR has two concepts that in Dutch are both translated as “producent”, and that is exactly where things go wrong in cross-border traffic. There is one manufacturer in the entire EU: the party that designs or has the packaging made under its own name or brand. There is one producer per member state: the party that first places the packaging on the market there and bears the EPR obligation there. See roles under the PPWR.
If you place packaging on the market in a member state where you are not established, you must appoint an authorised representative there — in Germany a Bevollmächtigter.
Three cases
Case 1. A Dutch company has packaging made in Germany and sells only in the Netherlands. The Dutch company is the manufacturer. The German converter is merely a supplier. It is the producer in the Netherlands and registers with Verpact. No LUCID needed.
Case 2. The same company now also sells in Germany. Now it is also a producer in Germany: appoint a Bevollmächtigter, LUCID registration, sign up with a dual system. From the first shipment, even at three hundred kilos. The Dutch threshold of 50,000 kg plays no role here whatsoever.
Case 3. A Dutch webshop ships directly to German consumers. Distance selling. LUCID registration has been mandatory since 1 July 2022, and without registration a sales ban applies. The shipping box counts.
What the PPWR changes about this
From 12 August 2026 the PPWR harmonises the substantive requirements: the same substance standards, the same traceability obligation, the same declaration of conformity, the same recyclability grades from 2030. What is called recyclable in Germany will also be recyclable in the Netherlands. The registration obligation becomes EU-wide but remains nationally implemented. What does not change: the German absence of a threshold and the Dutch threshold of 50,000 kg are national EPR choices. One packaging that meets the PPWR meets it in both countries. One registration is not enough.