German EPR for Shopify stores outside Germany: what you actually have to do
Most guidance on German packaging law is written for German companies, which is why so many merchants outside Germany assume none of it is theirs. It is. The obligation attaches to the act of placing a filled packaging on the German market for the first time, not to where your business is registered. Since 12 August 2026 the rules live in the Verpackungsrecht-Durchführungsgesetz (VerpackDG), which replaced the VerpackG - and it added one duty that applies only to sellers like you.
The short version
- There is no de-minimis threshold. One parcel of physical goods to a German consumer is enough to be in scope.
- Three separate duties, at three different places: registration (§ 6), system participation (§ 7) and data reporting (§ 9).
- No establishment in Germany? An authorised representative is now mandatory, appointed before your first shipment (§ 5 para. 2).
- The representative cannot do your registration - that one is expressly excluded and stays yours.
- Under 10 tonnes a year, you report once, by 1 June of the following year (§ 9 para. 2).
1. Why this applies to a shop outside Germany
The obligation follows the packaging, not the seller. Anyone who commercially places goods-filled packaging on the German market for the first time - packaging that typically ends up as waste at a private consumer - is a producer in the meaning of the law. A store in Prague, Antwerp, London or Austin shipping to German consumers does exactly that, and is therefore a producer for those shipments.
Scope is broader than the box the product came in. It covers the product packaging, any outer packaging and the shipping material: the carton, the tape, the void fill, the poly bag, the label. There is still no volume below which you owe nothing at all. Below 10 tonnes a year what changes is not whether you report but when and how often, which is section 4 below.
2. Three duties that are constantly confused
Almost every expensive mistake in this area comes from treating these as one thing. They are three, in this order, and two of them are not with the same organisation.
| Duty | Where | With whom |
|---|---|---|
| Registration in the LUCID packaging register | § 6 VerpackDG | Zentrale Stelle Verpackungsregister (a public body) |
| System participation (the licensing contract) | § 7 VerpackDG | A dual-system operator (a private company) |
| Data reporting of the masses you placed on the market | § 9 VerpackDG | Your dual system, and the register |
Signing a licensing contract does not register you. Registering does not license anything. A merchant who has done only one of the two is not half compliant; they are missing a duty whose absence carries its own fine, and without a registration number there is a prohibition on distribution regardless of what else is in order.
3. The rule that is new for you: a mandatory authorised representative
Under the old law, a foreign producer could appoint an authorised representative. § 5 para. 2 VerpackDG says producers without an establishment in Germany must appoint one for their extended producer responsibility, and must do so before first placing a packaging on the German market. For shops in Austria, Switzerland, the Czech Republic, Poland, the Netherlands - or anywhere outside Germany - this is the single most consequential change in the new law.
Two details are easy to miss. The mandate has to be granted in writing and in German (§ 5 para. 4). And the registration under § 6 is expressly excluded from what a representative may take over: you perform it yourself, with your own credentials, even after appointing one. If a service provider offers to "handle everything including registration", that part is not something they are permitted to do for you.
Transition dates, if you were already registered
- Newly obligated because of the new law: register by 12 September 2026.
- Already registered under the old law: your registration continues to count, but changes must be filed by 12 November 2026.
4. One deadline a year for most stores: 1 June
§ 9 para. 2 VerpackDG is the practical change that affects the most Shopify stores. If you placed less than 10 tonnes of system-participation packaging on the market in the previous calendar year, you are released from reporting after every system participation. Instead you report the whole calendar year in one submission by 1 June of the following year.
Ten tonnes of packaging is a great deal for a direct-to-consumer store; the large majority sit well below it. For them the practical picture is a single date in the year. Be careful with older guidance here: articles, law-firm FAQs and explainer videos written before August 2026 cannot mention this deadline, because it did not exist. If a source still cites § 9 VerpackG for registration, it predates the change.
5. What a report actually contains
A data report carries your registration number, the name of your system, the period, and the mass per material type. The breakdown follows § 42 para. 2 sentence 1 VerpackDG: glass; paper, board and cardboard; ferrous metals; aluminium; beverage carton packaging; other composite packaging; plastics - with remaining materials combined into a single figure.
One change is already scheduled: on 1 January 2027 category 5 is renamed from "beverage carton packaging" to "liquid cartons". That is more than a word - the new wording covers cartons for liquids that are not beverages, so some packaging moves category.
6. What it costs to get it wrong
The figure quoted everywhere is "up to €200,000", and it is real, but it does not apply to every breach. § 66 para. 3 VerpackDG grades it:
| Breach | Provision | Fine up to |
|---|---|---|
| No participation in a dual system | § 7 para. 1 sentence 1 | €200,000 |
| Missing, incorrect, incomplete or late registration | § 6 para. 1 sentence 1 | €100,000 |
| Data report missing, incorrect, incomplete or late | § 9 | €10,000 |
In practice the fine is rarely the real exposure. Without a registration number there is a prohibition on distribution, and marketplaces check whether their sellers are registered. Losing a sales channel costs more than the penalty does.
7. Where the numbers come from in a Shopify store
The legal part above is the same for everyone. The part that is specific to running a Shopify store is that nobody weighs parcels: the mass per material type has to be derived from what you already know about your products and your shipping.
That derivation needs three things. A packaging profile per product - what the item itself is packed in, by material and weight. A shipment profile - the boxes, tape and void fill you actually ship in. And the fulfilments themselves, restricted to the ones that went to Germany, because only those count towards the German figures.
None of that is hard in principle, and all of it is tedious to keep straight by hand for a full calendar year - which is the problem PackRegistry exists to solve. It reads your fulfilments, applies the packaging you mapped once, and produces the LUCID XML together with a matching dual-system summary and the evidence behind every figure. You review and submit; the app does not file anything on your behalf, and it cannot: that part is yours by law.
Independent software, not legal advice
PackRegistry prepares calculations and export files. It is not a regulator, a dual system, an authorised representative, an auditor or a law firm, and this article is not legal advice. For an ambiguous case - and cross-border constellations produce plenty - ask a qualified adviser.
Next steps
- Confirm whether you have an establishment in Germany. If not, appoint an authorised representative in writing and in German, before your next shipment.
- Register yourself in LUCID under § 6 - this one you cannot delegate - and keep the registration number.
- Contract with a dual system for the packaging you place on the German market.
- Estimate last year's volume against the 10-tonne line, so you know whether your deadline is 1 June or every participation.
- Decide now where the per-material masses will come from, before the reporting period ends and the fulfilments are history.
Two companion articles go deeper on the German side of this, in German: what changed on 12 August 2026 and the LUCID registration step by step.
Sources
Gesetz zur Anpassung des Verpackungsrechts und anderer Rechtsbereiche an die Verordnung (EU) 2025/40 of 13 July 2026, BGBl. 2026 I no. 207, published 17 July 2026 - article 1 (VerpackDG), articles 7 and 8 (entry into force, repeal). VerpackDG § 5 (engagement of third parties and authorised representation), § 6 (registration), § 7 (system participation), § 9 (data reporting), § 42 para. 2 (material types), § 66 (administrative fines). Zentrale Stelle Verpackungsregister: verpackungsregister.org.