Extended Producer Responsibility (EPR) is more than a buzzword - it defines who in your supply chain pays for packaging waste, who must register, and who risks fines, back payments or even sales bans if things go wrong.

Germany's strict Packaging Act (VerpackG) makes the clear allocation of the roles producer, manufacturer and importer the centerpiece of any EPR compliance strategy. Many FMCG companies overlook how quickly they are classified as a "producer" for EPR purposes in different countries - and thus become both reportable and liable to pay fees at the same time.

EPR (Extended Producer Responsibility) is an environmental policy approach under which producers assume responsibility and bear costs across the entire product life cycle - particularly for collection, recycling and disposal

This guide gives you practical answers to:

  • how to correctly understand the meaning of EPR for packaging,
  • how the roles producer/manufacturer/importer differ - especially in the EU and Germany,
  • how to systematically determine your EPR roles per product and market,
  • how EPR registration in Germany (LUCID) works,
  • and how to manage EPR compliance efficiently using structured packaging data and digital solutions such as the Packa software.

Note: This article provides guidance on packaging and EPR but does not constitute legal advice. If you are unsure, seek expert legal counsel.

Prerequisites: What you should clarify before you start

Before you begin, make sure the following internal information is available:

  • Overview of your packaging portfolio (SKU list including all relevant packaging)
  • Representation of your supply chain by product line:
    • Who owns the brand?
    • Where does filling/packaging take place?
    • Who supplies which countries (entities, distributors, online channels)?
  • List of existing EPR registrations (e.g. LUCID for Germany, other national registers)
  • Existing contracts with dual systems/PROs (Producer Responsibility Organisations)
  • Responsibilities for:
    • Packaging development
    • Procurement / supplier management
    • Sustainability / CSR
    • Legal / compliance

This foundation allows you to assign roles clearly - and avoid endless case-by-case debates.

Step 1: Understand EPR basics and key role definitions

1.1 What EPR means in the packaging context

At EU and national level, the principle is: whoever places packaging on the market finances its collection and recovery. Each EU country implements this principle through its own legislation and take-back systems.

In Germany, the Packaging Act (VerpackG) has implemented extended producer responsibility for packaging since 2019. Producers must register, license their packaging and report quantities

The key question is not "if", but in which countries am I a producer, and for which packaging?

1.2 Producer vs. manufacturer vs. importer - EU and PPWR perspective

With the new EU packaging regulation and the PPWR, the roles along the supply chain are becoming even more clearly defined. Packa has already described this system in detail for the PPWR. In simplified terms:

  • Producer (manufacturer in the sense of placing on the market): The legal entity that places packaging or packaged goods on the market of an EU member state for the first time - often the brand owner or the importer.
  • Manufacturer (manufacturer in the technical sense): Produces packaging components (e.g. bottles, folding boxes) - but is not automatically subject to EPR.
  • Importer: Brings packaged products from non-EU countries into the EU. Becomes the "producer" when the foreign brand owner is not established in the respective country.

The PPWR definition of "producer" covers manufacturers, importers or distributors who make packaging available for the first time in a member state under their own name or brand

These terms form the foundation for later determining who is subject to EPR in each country.

1.3 EPR in Germany: Specifics of the Packaging Act (VerpackG)

In Germany, the Packaging Act refers to "manufacturers", but it generally means the party that first places the packaging on the market:

  • A manufacturer is anyone who first places filled, system-participation-obligated packaging on the market in Germany on a commercial basis, where the packaging typically becomes waste at private end consumers.

Depending on the business model, this may be the brand owner, online retailer or importer.

Step 2: Map your business model and supply chain

Define your value chain precisely:

  1. Define product groups (e.g. beverage cans, tubes, food packaging, shipping cartons)
  2. Record packaging types for each product (sales and shipping packaging, possibly reusable packaging)
  3. Map supply chains by market:
    • Who manufactures?
    • Who is the brand owner?
    • Which legal entity supplies which market? (direct distribution, subsidiary, distributor, online)
  4. Assign legal entities

Tip: Visualize the supply chains for each product group on a single page - this forms the basis for cross-country allocation of "producer" and "importer" roles.

Digital systems such as digital packaging management with Packa enable you to document these relationships systematically and in a data-driven way.

Step 3: Who counts as a "manufacturer" under the German Packaging Act?

3.1 Core principles

For EPR in Germany, the following applies:

  • You are a manufacturer if you
    • commercially distribute filled sales or secondary packaging
    • for the first time in Germany, and
    • this packaging becomes waste at private end consumers.

Shipping packaging in e-commerce is also included.

Anyone who places system-participation-obligated packaging on the market in Germany must register in the LUCID packaging register and additionally participate in a dual system

3.2 Typical constellations in FMCG and retail

  1. Brand owner with German production

    • Production under your own brand, sold through retail or directly.
    • You are the manufacturer under the Packaging Act - registration and participation are required.

  2. Private label production for retailers

    • Filling on behalf of a retailer, sold under the retailer's brand.
    • Typically, the retailer is the manufacturer and assumes EPR obligations.
    • Clarify contractually who carries which responsibilities.

  3. Direct-to-consumer sales via online shop from Germany

    • Shipping to end consumers in Germany.
    • You are responsible for product and shipping packaging as the manufacturer.

  4. Dropshipping via platforms/marketplaces

    • The party that ships is considered the manufacturer if it delivers directly to end consumers.

Common pitfall: If roles are not clearly allocated, both parties may report packaging - leading to double fees.

Tip: Agree and document clearly who reports which volumes and who pays the corresponding fees.

Step 4: Identify your importer role for EPR in the EU

For imports from non-EU countries into the EU:

  • The importer brings packaged goods across the EU external border and, if the brand owner is not established in the respective EU country, is usually deemed the producer.
  • For each destination country, check whether you or your partner fulfils the producer role and must register.

Especially if you manage multiple brands, a central, digital management approach is recommended - for example with an EPR matrix and structured packaging data management.

Step 5: Separate technical manufacturer from producer placing packaging on the market

Do not confuse the technical packaging manufacturer with the EPR-liable producer/manufacturer:

  • Manufacturer: Produces packaging components (e.g. bottles, folding boxes, films), and provides data and documentation.
  • Producer/manufacturer under EPR/VerpackG: Places filled packaging on the market and assumes the fee-liable role.

According to the Packa PPWR guide, the manufacturer supplies the necessary packaging data (material, specifications, compliance), while the brand owner is responsible for registration and reporting.

Tip: Clearly distinguish internally between

  • Suppliers/manufacturers: Responsible for providing verified packaging data
  • Producers/brand owners: Responsible for EPR registration, fees and reporting

This way, you structure data collection and legal responsibility effectively.

Step 6: Systematically document roles by market

Avoid Excel chaos and document your roles consistently across countries:

6.1 Define an EPR roles matrix

Capture the following fields:

  • Product group / SKU
  • Country of sale
  • Brand owner
  • Producer/filler
  • Importer
  • EPR producer under national law
  • National registration (e.g. LUCID in Germany)
  • PRO / dual system
  • Internal contact person

With such a matrix you maintain an end-to-end overview - beyond EPR in Germany. Packa highlights country-specific differences in the article "EPR fees in Europe: What manufacturers need to know for 2026".

6.2 Secure your data foundation

Ensure that your packaging data is complete and structured:

  • Materials and quantities for each component
  • Weights
  • Recyclability and recycled content
  • Allocation to entities and markets

Packa's feature article "Ensuring EPR compliance for 2026: structured data collection" shows how structured data becomes the foundation for robust EPR and PPWR compliance.

Step 7: EPR registration in Germany (LUCID) - how to proceed

EPR registration in Germany consists of a few defined steps:

All manufacturers under the Packaging Act must register in the LUCID register of the Central Packaging Register Office (ZSVR) before placing system-participation-obligated packaging on the market for the first time

After registration, you receive a LUCID number. Online marketplaces and fulfilment service providers have been actively requesting this number since 2022

7.1 Step-by-step: LUCID registration

  1. Check whether you are a manufacturer under the Packaging Act (see Step 3)
  2. Compile company data (legal name, legal form, address, commercial register/VAT ID, responsible person, brands used)
  3. Register online with LUCID (exclusively digital via ZSVR)
  4. Select a dual system and sign a licensing contract (estimate quantities, conclude contract, pay fees)
  5. Submit quantity reports (forecast at the start of the year, report actual annual quantities)
  6. Maintain your data on an ongoing basis (e.g. record changes to brand, legal form, responsible persons; store all documents in an audit-proof way)

Tip: Store your LUCID number, dual system and EPR roles per item directly in your digital packaging management system to manage reports and audits efficiently.

Step 8: Typical mistakes and cost traps - and how to avoid them

Mistake 1: Unclear roles

  • Problem: EPR/Packaging Act responsibilities between brand owner, contract filler and retailer are not clearly defined.
  • Consequence: Double reporting, double fees or, in the worst case, no reporting at all - with the risk of fines and market bans.

Tip: Hold a role clarification workshop with all stakeholders and define responsibilities contractually.

Mistake 2: The misconception that "small quantities do not count"

Even the smallest quantities must be reported - registration and system participation apply from the very first piece of system-participation-obligated packaging. Exemptions exist only for certain reporting obligations (e.g. completeness declarations).

Mistake 3: Forgetting shipping packaging

Shipping cartons, void fill and shipping labels are often missing from the balance. These are relevant for EPR/the Packaging Act if they generate waste at the end consumer.

Mistake 4: Relying on Excel instead of structured data

Decentralized data management leads to inconsistencies and errors.

In "Why packaging management tools like Packa are essential today", Packa explains why digital packaging management is central for EPR and PPWR.

Mistake 5: Seeing EPR only as a cost center

Through eco-modulation and country-specific fees, recyclability, materials and recycled content directly influence the amount of your EPR charge. Structured data management helps you

  • reduce assortment complexity,
  • replace expensive materials,
  • increase recyclability and reduce fees over time.

Packa's EPR fee guide provides a practical overview of major cost drivers across Europe.

Step 9: Use digital packaging management - keep EPR roles and data under control

EPR compliance is fundamentally a data and process management challenge:

  • Who takes which role in which country?
  • Which components belong to which product?
  • How do design changes affect fees and recyclability?

Experience shows that companies without centralized packaging data management have incomplete packaging data for 30-70% of their items - a significant risk for EPR and PPWR compliance

The Packa software supports you with:

  • Central digital packaging management for all markets
  • AI-based specification digitization (Excel, PDF, ERP)
  • Defining EPR roles and registrations per item and market
  • Automated compliance checks for PPWR and EPR
  • Audit-ready, tamper-proof documentation

The feature article "Ensuring EPR compliance for 2026: structured data collection" shows how central systems secure data quality and auditability.

Talk to Packa

Next steps for your team

  • 1. Run a roles workshop
    • Procurement, packaging engineering, sustainability and legal teams pool their expertise to develop consistent role models for all key markets.
  • 2. Build your roles matrix and data foundation
    • Document product groups, countries, roles and registrations in a structured way.
  • 3. Secure your EPR compliance in Germany
    • Check whether all relevant entities are registered in the LUCID register and with dual systems.
  • 4. Establish structured packaging data management
  • 5. Develop your EPR and fee strategy

FAQ: Frequently asked questions on producer, manufacturer and importer roles in EPR

1. What does EPR mean specifically in the context of packaging?

EPR obliges producers or entities placing packaging on the market to bear the costs for collection, sorting and recovery of packaging waste.In the EU, this is implemented nationally - in Germany via the Packaging Act and dual systems

2. Who is considered a "manufacturer" under the German Packaging Act?

Any legal entity that commercially places filled sales or secondary packaging on the market in Germany for the first time, where such packaging can become waste at private end consumers - including brand owners, online retailers or importers - is considered a manufacturer.

3. Is an EPR/LUCID number required even for small quantities?

Yes, registration in the LUCID register is required from the very first piece of system-participation-obligated packaging - regardless of quantity. There are only simplifications for specific reporting obligations.

4. Can my supplier take over my EPR obligations?

This depends on contractual arrangements and national regulation. In Germany, retailers with private labels can agree with their contract manufacturers that the latter will report. Ultimately, however, the statutory manufacturer remains responsible; authorities always address the primary obligated party.

5. What are the consequences of non-compliance in Germany?

Violations of the Packaging Act can lead to fines of up to €200,000 per case, sales bans, delisting on marketplaces and reputational damage

You should therefore structure roles, registrations and packaging data early and digitally. Solutions like Packa help you manage EPR and PPWR compliance in a data-driven, efficient and audit-proof way.

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