compliance teamEvery German dual-system contract expires on 31 December 2026
Step 1
Check your contract end date
Step 2
Confirm the representative position
Step 3
Re-contract for 2027
Step 4
File the planned volumes for the new year
| Control | Evidence to retain |
|---|---|
| Scope | Entity, product, channel, stream and source |
| External action | Version, date, authorised filer and issued receipt |
| Maintenance | Source data, approval, invoice and next deadline |
The contract cliff
Section 68(1) VerpackDG keeps system-participation contracts concluded under the repealed packaging act valid at the latest until the end of 31 December 2026. Every producer selling into Germany, domestic or foreign, therefore needs a contract under the new law for 2027.
This is not a renewal in the ordinary sense. It is a legal expiry with a fixed date, and it lands on the whole market at once. Expect systems to be busy in the fourth quarter and plan the re-contracting before then rather than into it.
The other transitional dates
Producers newly caught by the act were required to register by 12 September 2026. Registration master data must be updated by 12 November 2026. The penalty tier that applies to marketplaces and fulfilment providers for direct PPWR breaches begins only on 12 February 2027.
Whether the 12 November date covers adding an authorised representative to an existing registration is not stated explicitly. It is a reasonable reading and we treat it as an interpretation, not as a deadline we assert. Anyone quoting it as settled law has not read the section.
What to do with the window
If you already hold a register entry without a representative, the same window solves both problems: agree the mandate, name the representative, and put a 2027 contract in place with the volumes you actually expect.
If you are not registered at all, the sequence is fixed: mandate first, because a first registration cannot be completed with the representative field empty, then the guided registration session, then the contract and the planned-volume report.
Conclusion
Scope comes before a form. Connect the legal entity, its German establishment, the product, the sales channel and the EPR stream to the rule that actually applies.
Evidence must remain traceable. Keep source data, versions, approvals, filings, receipts and every record issued by an external body.
Third-party decisions are never guaranteed. The packaging register, the central agency, the dual systems and the marketplaces control their own procedures, timing and decisions.