What does the Packaging Act (LUCID) have to do with the PPWR?

LUCID and the PPWR are two legally independent obligations — both affect companies that place packaging on the market, but at different levels.

The German Packaging Act (VerpackG) requires you to license system-participation-obligatory packaging with a dual system (e.g. Der Grüne Punkt, Landbell) and to register in the Central Packaging Register (ZSVR) under LUCID. This obligation remains fully in force after 12 August 2026 — the PPWR does not repeal the VerpackG.

The PPWR (Regulation (EU) 2025/40) operates at EU level and supplements national law with new requirements: minimum recycled content, design requirements for recyclability, restrictions on single-use formats, and — from 12 August 2026 — mandatory QR code labelling with a digital product passport for certain packaging types.

In practice, a dual obligation arises: you must remain registered in the ZSVR and demonstrate system participation (LUCID obligation), while at the same time your packaging must comply with the new PPWR design and labelling requirements. Fulfilling only one of the two obligations constitutes a breach of the other legal basis.

Particularly relevant for B2B supply chains: PPWR compliance of your packaging does not replace the LUCID registration of your buyers — every company placing goods on the market must independently verify both requirements.

For a binding assessment of your specific packaging portfolio, please contact your local Chamber of Commerce and Industry (IHK).