Germany vs Washington EPR: Rules Compared
Last verified
Germany and Washington both run packaging EPR, but the rules differ. Both require producers to register. Germany asks for its first annual report earlier, on May 15 against May 31 in Washington. Every figure below links to its primary source.
Germany and Washington side by side
2 of 9 rows have a verified figure on each side of Germany and Washington; a cell reads “not yet published” when a side has none, and an exemption row reads “none recorded; see thresholds” when no exemption is on record.
| Measure | Germany | Washington | Stricter |
|---|---|---|---|
| Registration duty | Required | Required | Same |
| Producer organisation | more than one producer responsibility organisation | one producer responsibility organisation | Not comparable |
| Lowest revenue exemption | none recorded; see thresholds | $5,000,000 | Not comparable |
| Lowest weight exemption | none recorded; see thresholds | 907.2 kg | Not comparable |
| First annual report date | May 15 | May 31 | Germany |
| Published penalties | not yet published | 1 published | Not comparable |
| Report file | xml | csv | Not comparable |
| Paper fee, cheapest matched rate | not yet published | not yet published | Not comparable |
| Plastic fee, cheapest matched rate | not yet published | not yet published | Not comparable |
Both programmes require a producer to register, in Germany and in Washington.
The earliest annual report date is May 15 in Germany and May 31 in Washington, 16 days apart. Germany leaves less time to prepare, so its data has to be ready first.
Who runs the programme in Germany and Washington
Who collects and who the producer files with, in Germany and then Washington.
| Aspect | Germany | Washington |
|---|---|---|
| Regime | Packaging producer responsibility: register in LUCID, participate packaging subject to system participation in a dual system, and report volumes | Washington Recycling Reform Act, chapter 70A.208 RCW |
| Regulator | Zentrale Stelle Verpackungsregister (ZSVR), which runs the LUCID Packaging Register; competent state authorities enforce | Washington State Department of Ecology |
| Producers obligated | Yes | Yes |
| Registration | Required, LUCID Packaging Register (ZSVR) | Required, Producer registers with a PRO; the PRO registers with Ecology |
| Producer organisation | more than one producer responsibility organisation; membership optional | one producer responsibility organisation: Circular Action Alliance; membership required |
| Transfer of responsibility | Allowed | not yet published |
| Revenue counted as | not yet published | worldwide gross revenue, USD, prior fiscal year |
| Who counts as the producer | other: manufacturer or brand owner, manufacturer, importer, first distributor, authorised representative; primary: manufacturer or brand owner, importer, first distributor, authorised representative; secondary: manufacturer or brand owner, importer, first distributor, authorised representative; service: manufacturer or brand owner, manufacturer, importer, first distributor, authorised representative; shipping: manufacturer or brand owner, packer and shipper, importer, first distributor, online marketplace seller, authorised representative; tertiary: manufacturer or brand owner, manufacturer, importer, first distributor, authorised representative | primary: manufacturer, brand licensee, brand owner, importer |
The two programmes are organised differently. Germany uses more than one producer responsibility organisation; Washington uses one producer responsibility organisation. For a seller in both, that usually means two different counterparties, two different sign-up routes and two different sets of terms to read before the first report is due.
What Germany and Washington cover, side by side
Each row below is one published feature of the two programmes; a cell reads “not yet published” when Germany or Washington has no verified entry for it in the dataset.
| Aspect | Germany | Washington |
|---|---|---|
| Materials covered | paper and card, glass, plastic, steel, aluminium, fibre based composite, other | packaging, paper products |
| Product classes covered | primary packaging, secondary packaging, shipment packaging, tertiary packaging, reusable packaging | packaging, paper |
| Sales channels addressed | retail, wholesale, online, online marketplace | physical retail, remote sale, other distribution |
| Producer duty: primary packaging | manufacturer_brand_owner; importer; first_distributor; authorised_representative | manufacturer; licensee; brand_owner; importer |
| Producer duty: secondary packaging | manufacturer_brand_owner; importer; first_distributor; authorised_representative | not yet published |
| Producer duty: tertiary packaging | manufacturer_brand_owner; manufacturer; importer; first_distributor; authorised_representative | not yet published |
| Producer duty: shipping packaging | manufacturer_brand_owner; packer_shipper; importer; first_distributor; online_marketplace_seller; authorised_representative | not yet published |
| Producer duty: service packaging | manufacturer_brand_owner; manufacturer; importer; first_distributor; authorised_representative | not yet published |
| Producer duty: other packaging | manufacturer_brand_owner; manufacturer; importer; first_distributor; authorised_representative | not yet published |
| Excluded from scope | not yet published | exempt materials |
| Exemption 1 | not yet published | A de minimis producer is under one ton, or under the global revenue limit, or an agricultural employer within limits. |
| Exemption 2 | not yet published | Registered 501(c)(3) and 501(c)(4) organizations are excluded from the producer definition. |
Thresholds and exemptions in Germany and Washington
Every verified threshold Germany and Washington publish, as each states it.
| Place | Measure | Amount | Effect | Basis as published |
|---|---|---|---|---|
| Germany | packaging tonnage | 80 tonnes | declaration-of-completeness trigger | glass placed on the German market in the previous calendar year (reached or exceeded) |
| Germany | packaging tonnage | 50 tonnes | declaration-of-completeness trigger | paper, paperboard and cardboard in total, previous calendar year (reached or exceeded) |
| Germany | packaging tonnage | 30 tonnes | declaration-of-completeness trigger | ferrous metals, aluminium, plastics, beverage cartons and other composites in total, previous calendar year (reached or exceeded) |
| Germany | packaging tonnage | 10 tonnes | reduced duty | packaging subject to system participation made available for the first time in the previous calendar year |
| Washington | packaging tonnage | 1 short ton | exempt below | covered materials introduced, most recent fiscal year |
| Washington | revenue | $5,000,000 | exempt below | global gross revenue, prior fiscal year |
Washington exemption: A de minimis producer is under one ton, or under the global revenue limit, or an agricultural employer within limits. It does not have to be applied for.
Washington exemption: Registered 501(c)(3) and 501(c)(4) organizations are excluded from the producer definition. It does not have to be applied for.
Read the basis column first: the same amount can exempt a producer in one programme and only simplify its report in another.
Fees per kilogram for shared materials
Neither Germany nor Washington has a verified per-kilogram fee schedule in the dataset yet. Until both sides publish per-kilogram rates for the same material class, a fee comparison between Germany and Washington would mean inventing a figure, and this page does not do that.
Deadlines in Germany and Washington
Each verified date, with the period it covers when one is given.
| Place | Kind | Date | Covers |
|---|---|---|---|
| Germany | report | June 1, 2027 | calendar year 2026 |
| Germany | report | December 31, 2026 | calendar year 2027 |
| Germany | report | May 15, 2027 | calendar year 2026 |
| Washington | other | March 1, 2026 | not yet published |
| Washington | report | May 31, 2026 | not yet published |
| Washington | registration | July 1, 2026 | not yet published |
| Washington | other | October 1, 2028 | not yet published |
| Washington | other | March 1, 2029 | not yet published |
| Washington | other | January 1, 2030 | not yet published |
| Washington | payment | February 15, 2031 | not yet published |
| Washington | payment | February 15, 2032 | not yet published |
The earliest annual report date is May 15 in Germany and May 31 in Washington, 16 days apart. Germany leaves less time to prepare, so its data has to be ready first.
Penalties in Germany and Washington
What each side has published; a side without an amount says so.
Washington penalty for producer violating chapter 70A.208 RCW: up to $1,000 per day.
Report formats in Germany and Washington
How the report file for Germany compares with the one for Washington.
| Aspect | Germany | Washington |
|---|---|---|
| Layout | LUCID producer volume report (XML upload, section 10 VerpackG) XML interface 1.0, guide version 1.3 (12 August 2026), VerpackG material codes (reports 2019 to 2026) | Washington interim producer supply report by material class 2026-09-29 (interim, built from CAA guidance) |
| Recipient | Stiftung Zentrale Stelle Verpackungsregister (ZSVR), LUCID packaging register | Circular Action Alliance (Washington PRO) |
| How it is submitted | LUCID XML upload. The customer signs in, uploads the file, checks the displayed data and confirms. | CAA producer portal. The customer signs in and submits. |
| File type | xml | csv |
| Encoding | utf-8-sig | utf-8 |
| Delimiter | not yet published | , |
| Decimal separator | , | . |
| Columns | 8 | 4 |
| Required columns | 8 of 8 | 4 of 4 |
| Weight unit | kg | lb |
| Period basis | calendar year | calendar year |
Germany report specification: XML producer volume report with elements VersionNoInterface, PackagingTypeCode, TypeOfReportCode, ReportingPeriodFrom, ReportingPeriodTo and one SystemOperator with its SystemOperatorID and a Material list (MaterialCode, Mass).
The two layouts differ in file shape as well as in columns, so a report built for Germany cannot be sent to Washington unchanged. Each report is built from the same underlying measurements and exported separately.
Which to plan for first, Germany or Washington
Plan around the earlier report date first. Germany asks for its first annual report on May 15, before Washington, so its data has to be ready first.
Questions about comparing these two programmes
Is Germany or Washington stricter on packaging EPR?
Both require producers to register. Germany asks for its first annual report earlier, on May 15 against May 31 in Washington.
Do I register in both Germany and Washington?
Germany requires producers to register. Washington requires producers to register.
How do the fees per kilogram compare in Germany and Washington?
The dataset does not hold per-kilogram rates for the same material class on both sides, so this page does not compare fees.
Which deadline comes first, Germany or Washington?
The earliest annual report date is May 15 in Germany and May 31 in Washington, 16 days apart. Germany leaves less time to prepare, so its data has to be ready first.
How these figures are made
Sources
- verpackungsregister.org: system participation retrieved
Original wording: you must finance the recycling of your packaging by participating that packaging in a system.
Original wording: You can conclude your system participation agreement with the system operator of your choice.
Original wording: you are required to conclude a system participation agreement with a system operator.
- verpackungsregister.org: declaration of completeness retrieved
Original wording: The Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR) and the competent state authorities
Original wording: Glass: 80 tonnes
Original wording: Paper, paperboard, cardboard (PPC) in total: 50 tonnes
Original wording: Ferrous metals + aluminium + plastics + beverage cartons + other composites (lightweight packaging) in total: 30 tonnes
Original wording: by no later than 15 May of any given year for the previous year.
- verpackungsregister.org: find out about registrations retrieved
Original wording: If you are distributing packaged goods in Germany, you have to be registered with the LUCID Packaging Register.
Original wording: you must register with the LUCID Packaging Register. Registering is free of charge.
Original wording: There are two different packaging categories: packaging subject to system participation and packaging not subject to system participation.
- verpackungsregister.org: distinguishing between manufacturers producers retrieved
Original wording: A producer is every natural or legal person who, as a manufacturer, importer or distributor, makes a unit of packaging available for the first time
- verpackungsregister.org: data reporting retrieved
Original wording: A simplified reporting requirement applies to producers who made available less than 10 tonnes of packaging subject to system participation
Original wording: Year-end volume reports for the previous year (actual volumes) can only be filed up to 1 June.
Original wording: Initial planned volume reports for the following year can only be filed by 31 December of the current year.
- circularactionalliance.org: washington retrieved
Original wording: required in the Recycling Reform Act
Original wording: By January 1, 2026 Washington Department of Ecology must establish and appoint the initial membership of the advisory council.
Original wording: July 1, 2026 Washington regulatory deadline for Producers to register with a PRO.
Original wording: By March 1, 2026 A PRO must register with Washington Department of Ecology on behalf of its producers.
Original wording: By May 31, 2026 Reporting (Interim State Addendum Signed & Simplified Reporting)
- app.leg.wa.gov: default retrieved
Original wording: After July 1, 2026, be a member of a producer responsibility organization registered in this state
Original wording: Has a global gross revenue, not including on-premises alcohol sales, for the prior fiscal year of
Original wording: the producer is the person that manufactures the item
Original wording: In their most recent fiscal year introduced less than one ton of covered materials
Original wording: Until January 1, 2031, less than $5,000,000
Original wording: "De minimis producer" means a producer that
Original wording: Registered 501(c)(3) charitable organizations and 501(c)(4) social welfare organizations
Original wording: By October 1, 2028, and every five years thereafter, submit a plan that meets the requirements of this chapter
Original wording: Beginning March 1, 2029, a producer that is not a member in good standing with a registered producer responsibility organization
Original wording: By January 1, 2030, or within six months of plan approval, whichever is later, implement the plan approved by the department
Original wording: No less than 75 percent of the net costs by February 15, 2031
Original wording: No less than 90 percent of the net costs by February 15, 2032, and each year thereafter
Original wording: civil penalty of up to $1,000 per violation per day on any producer who violates this chapter
Original wording: "Covered material" means packaging and paper products introduced into the state.
- ecology.wa.gov: producer responsibility organization retrieved
Original wording: The Circular Action Alliance is the PRO representing producers in Washington. We encourage all potentially obligated producers to register with CAA.
- verpackungsregister.org: Anleitung XML Datenmeldung EN retrieved
Original wording: Mass: packaging material mass in kg to the third decimal place without thousands separators (decimal place demarcated with comma).
The free plan is enough to start. We estimate and prepare; you sign and submit.