VerpackG, PPWR and Compostable Packaging in Germany: An Importer’s Guide
A Munich distributor emailed us in April with one line: “Which certificate satisfies VerpackG — EN 13432, or the OK Compost one?” He had signed a trial order for bagasse clamshells; his consultant said he needed a “VerpackG certificate” before customs release. That certificate does not exist. His question hid three separate obligations that are easy to merge in your head and expensive in your paperwork.
We press bagasse and cornstarch tableware in Qingdao — roughly 2,500–3,000 tonnes a year for export, Germany included. We are not your legal adviser, but we sit on the supplier side of many German import files. Here is what evidence we hold, what an importer must file, and where “compostable” stops being a selling point.
PPWR and VerpackG are two layers, not two names for one thing
VerpackG is German national law — the Verpackungsgesetz, implementing EU packaging rules at member-state level. It governs how packaging placed on the German market is registered, licensed and reported.
PPWR is the EU-level regulation — Regulation (EU) 2025/40 on packaging and packaging waste — replacing the older Packaging and Packaging Waste Directive (94/62/EC) with directly applicable rules across member states. It needs no German transposition act, though German law still has to line up with it.
So VerpackG obligations apply now, while PPWR provisions phase in over a transition period. Check current application dates with the Zentrale Stelle Verpackungsregister or German trade counsel before planning around any PPWR deadline — timelines here have been negotiated and should be verified against a primary source.
The obligation chain: who is actually on the hook
A Chinese factory is not the obligated party in Germany. Obligations attach to whoever places packaging on the German market — normally the importer or the brand owner.
| Obligation | Who it falls on | Importer action |
|---|---|---|
| LUCID registration | First distributor on the German market | Register via the Zentrale Stelle Verpackungsregister before market placement; obtain your number |
| System participation (licensing) | Same party | Contract a dual system (Der Grüne Punkt, Interzero and others); license volumes by material |
| Volume reporting | Same party | Report quantities by material; keep data traceable |
| Material and claim evidence | Via the supplier | Hold EN 13432 reports and certification for any compostable claim |
| Downstream requests | Your customer | Pass on registration and licensing proof on request |
An importer cannot license without a registration number, nor register accurately without knowing the material and weight per unit arriving. That is where we come in — a per-SKU weight breakdown so the importer licenses volumes that match reality, not a guess.
Compostable is not automatically the preferred route in Germany
German packaging policy has historically favoured recycling through the dual system over composting. Compostable is not a blanket upgrade. For many applications the expectation is that packaging goes into the yellow bag or paper stream and is recycled — and a compostable item in the wrong stream can contaminate a recycling line.
Compostable foodservice ware earns its place where packaging is food-soiled, hard to recycle cleanly, and an organic waste stream exists to take it — catering, canteens, events, certain takeaway formats. That is narrower than the marketing suggests. Tell your customers plainly: compostable tableware is not a shortcut around VerpackG licensing. You still register and license. What it buys you is a defensible claim and a fit with organic streams — not an exemption.
What “compostable” has to mean to survive scrutiny
In the EU, “compostable” points to a defined standard, and the reference is EN 13432 — packaging recoverable through composting and biodegradation, covering disintegration, biodegradation, ecotoxicity and heavy metals. A defensible claim generally needs an EN 13432 test report from an accredited lab plus third-party certification against EN 13432 — commonly DIN CERTCO (issuing the “DIN-Geprüft industriell kompostierbar” and home-compostability marks) or TÜV Austria’s OK Compost programme (INDUSTRIAL and HOME).
We keep those reports and certificates per line, and we flag where a certificate covers a material nested inside a product — a sheet certificate does not automatically speak for a finished, pressed and coated clamshell. Our /certifications/ page lists which document travels with which SKU; the standards are unpacked in /compostable-certification-standards/.
One more distinction trips up claims: EN 13432 is fundamentally an industrial composting standard, while home-compostable marks are a separate certification. Print “kompostierbar” without saying where and a German reviewer will ask which stream (see /home-vs-industrial-composting/).
How a Qingdao factory supplies the evidence an importer needs
German customers generally need four documents per order: an EN 13432 test report naming material and product; certification (DIN CERTCO or TÜV Austria OK Compost); food-contact documentation, since food-contact and composting are separate questions; and a weight and material breakdown per SKU for accurate registration and licensing.
One concrete case: in 2024 a Hamburg importer licensed his volumes from a rounded catalog weight, then found the real per-unit weight on our 9-inch plate ran higher than the sheet figure. Small gaps multiply across a container. We now send a weighing sheet with the packing list on every German order, and his dual-system reporting matches to the unit. Bagasse typically runs two to three times a plastic price multiple; the saving is in compliance position and market access, not the invoice line (/blog/bagasse-vs-plastic-cost/).
Pre-shipment checklist for German importers
Before the first PO: confirm who is the obligated party; verify LUCID registration and hold the number; get a dual-system contract and license volumes by material; and collect EN 13432 reports and certification matching the exact SKU.
The logistics picture is covered in /export-shipping-bagasse-containers-from-china/; multi-market importers may find /blog/eu-ppwr-packaging-regulation-2026-guide/ and /blog/compostable-certifications-2026-guide/ useful.
FAQ: VerpackG, PPWR and compostable tableware in Germany
Is a Chinese manufacturer required to register in LUCID?
No. Registration sits with the German producer or first distributor — normally the importer or brand owner placing packaging on the market. A Chinese factory cannot register for you, though we can supply the data you need.
Does compostable packaging avoid dual-system licensing in Germany?
No. Compostable packaging on the German market is still packaging under VerpackG and still needs LUCID registration and system participation. It changes how the item is described and which stream suits it, not the obligation.
Which certificate should I ask my supplier for?
An EN 13432 test report plus third-party certification — DIN CERTCO or TÜV Austria OK Compost are the marks German reviewers recognise. Make sure it covers the finished product, not just the raw material.
Does PPWR replace VerpackG immediately?
No. PPWR (Regulation (EU) 2025/40) replaces the Packaging and Packaging Waste Directive with directly applicable EU rules, but its provisions phase in over a transition period, and VerpackG stays relevant during the ramp. Verify current dates with the Zentrale Stelle Verpackungsregister or German counsel.
Can I put a home-compostable claim on German packaging?
Only with certification for home compostability specifically. EN 13432 is primarily an industrial standard, so an EN 13432 report alone does not support a home-compostable claim.
Where does compostable foodservice ware actually make sense in Germany?
Where packaging is food-soiled, hard to recycle cleanly, and an organic waste stream exists to take it. Outside those, German policy leans toward recycling through the dual system.
Next step
If you need a supplier who arrives with EN 13432 reports, DIN CERTCO or TÜV Austria certification and per-SKU weight data already prepared, send us your SKUs and target volumes. We will ship samples with their documentation so your consultant can review the actual paper, not our summary of it. Start at /request-quote/, or use /sample-request/ to check the material first. Buyers weighing the wider picture can compare the /blog/uk-bagasse-tableware-wholesale-guide/ and /blog/bagasse-tableware-importers-usa-guide/ guides.
Note: regulatory positions described here are our understanding as a supplier, not legal advice. Verify VerpackG, PPWR and dual-system requirements with the Zentrale Stelle Verpackungsregister or qualified German counsel before you place packaging on the market.
