# Germany vs Washington EPR: Rules Compared

Last verified: November 5, 2026 · https://instica.com/epr/compare/germany-vs-washington

<a id="answer"></a>

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.

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## 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.

<a id="glance-table"></a>**Germany and Washington: the measures both programmes publish**

| 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 |

<a id="calc-registration"></a>Both programmes require a producer to register, in Germany and in Washington.

<a id="calc-report-date"></a>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.

<a id="programme"></a>

## Who runs the programme in Germany and Washington

Who collects and who the producer files with, in Germany and then Washington.

<a id="programme-table"></a>**Germany and Washington: how each programme is set up**

| 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 |

> **Not yet published**: Not yet published for Germany: how revenue is counted. Reason: No revenue test appears on the pages read. The value records that none was found, which is not proof that none exists.

> **Not yet published**: Not yet published for Washington: the rules on transferring responsibility. Reason: No transfer or delegation rule was found in the definition read. The PRO section allows a producer to designate a PRO, which is membership, not a transfer.

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.

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## 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.

<a id="scope-table"></a>**Scope, producer duties, categories, labelling and targets, Germany and Washington**

| 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. |

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## Thresholds and exemptions in Germany and Washington

Every verified threshold Germany and Washington publish, as each states it.

<a id="thresholds-table"></a>**Verified thresholds in Germany and Washington**

| 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 |

<a id="b-exemption-de-minimis-producer"></a>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.

<a id="b-exemption-nonprofits"></a>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.

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## 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.

> **Not yet published**: Germany: no verified per-kilogram fee schedule is in the dataset yet. Reason: Dual-system participation fees are set by each operator's contract and no public tariff has been retrieved; the fee engine asks for the customer's contracted rates instead of estimating.

> **Not yet published**: Washington: no verified per-kilogram fee schedule is in the dataset yet.

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## Deadlines in Germany and Washington

Each verified date, with the period it covers when one is given.

<a id="deadlines-table"></a>**Verified deadlines in Germany and Washington**

| 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.

<a id="penalties"></a>

## Penalties in Germany and Washington

What each side has published; a side without an amount says so.

> **Not yet published**: Not yet published for Germany: penalty amounts. Reason: The fine amounts sit in the statute, which was not readable. Nothing is recorded rather than guessed.

<a id="b-penalty-0"></a>Washington penalty for producer violating chapter 70A.208 RCW: up to $1,000 per day.

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## Report formats in Germany and Washington

How the report file for Germany compares with the one for Washington.

<a id="formats-table"></a>**Report file layouts for Germany and 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 |

<a id="a-format-spec"></a>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).

> **Not yet published**: Washington: the programme’s own report specification is not yet published. Reason: The PRO says Washington material reporting categories are not yet known, and the draft plan is not expected until 2028. Only the simplified interim reporting exists, and it is portal-only. The layout above is Instica’s working layout.

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.

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## 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.

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## Questions about comparing these two programmes

### <a id="q1"></a>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.

### <a id="q2"></a>Do I register in both Germany and Washington?

Germany requires producers to register. Washington requires producers to register.

### <a id="q3"></a>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.

### <a id="q4"></a>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.

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## How these figures are made

> **Estimate**: Instica measures, estimates and prepares. Every figure on this page is read from a sourced record or computed from one, and each carries its data quality. Converted amounts are approximate and name the exchange rate used. The customer signs and submits each report; Instica never stores regulator login details and never files on your behalf. This page is general information about published rules; confirm your own position with a qualified adviser.

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## Facts on this page

Each fact is a self-contained sentence with its source. Link to a fact with its anchor.

- <a id="a-regime"></a>Germany: the packaging rules sit in Packaging producer responsibility: register in LUCID, participate packaging subject to system participation in a dual system, and report volumes. [#a-regime](#a-regime)
  Value: Packaging producer responsibility: register in LUCID, participate packaging subject to system participation in a dual system, and report volumes · Source: https://www.verpackungsregister.org/en/system-participation-data-reporting/system-participation · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: you must finance the recycling of your packaging by participating that packaging in a system.
- <a id="a-regulator"></a>Germany: the regulator is Zentrale Stelle Verpackungsregister (ZSVR), which runs the LUCID Packaging Register; competent state authorities enforce. [#a-regulator](#a-regulator)
  Value: Zentrale Stelle Verpackungsregister (ZSVR), which runs the LUCID Packaging Register; competent state authorities enforce · Source: https://www.verpackungsregister.org/en/system-participation-data-reporting/declaration-of-completeness · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: The Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR) and the competent state authorities
- <a id="a-obligated"></a>Germany places an obligation on packaging producers. [#a-obligated](#a-obligated)
  Value: yes · Source: https://www.verpackungsregister.org/en/registration/find-out-about-registrations · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: If you are distributing packaged goods in Germany, you have to be registered with the LUCID Packaging Register.
- <a id="a-registration"></a>Germany: producers must register through LUCID Packaging Register (ZSVR). [#a-registration](#a-registration)
  Value: yes · Source: https://www.verpackungsregister.org/en/registration/find-out-about-registrations · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: you must register with the LUCID Packaging Register. Registering is free of charge.
- <a id="a-organisation"></a>Germany organises producer responsibility through more than one producer responsibility organisation; membership is not required. [#a-organisation](#a-organisation)
  Value: several competing organisations · Source: https://www.verpackungsregister.org/en/system-participation-data-reporting/system-participation · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: You can conclude your system participation agreement with the system operator of your choice.
- <a id="a-transfer"></a>Germany allows a producer’s obligation to be transferred to another party. [#a-transfer](#a-transfer)
  Value: yes · Source: https://www.verpackungsregister.org/en/system-participation-data-reporting/system-participation · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: you are required to conclude a system participation agreement with a system operator.
- <a id="a-hierarchy-other"></a>Germany: at the other packaging level the producer hierarchy names the manufacturer or brand owner, manufacturer, importer, first distributor and authorised representative (2026). [#a-hierarchy-other](#a-hierarchy-other)
  Value: manufacturer_brand_owner > manufacturer > importer > first_distributor > authorised_representative · Source: https://www.verpackungsregister.org/en/first-steps/distinguishing-between-manufacturers-producers · Retrieved: November 4, 2026 · Status: verified
  Verbatim quote: 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
- <a id="a-hierarchy-primary"></a>Germany: at the primary packaging level the producer hierarchy names the manufacturer or brand owner, importer, first distributor and authorised representative (2026). [#a-hierarchy-primary](#a-hierarchy-primary)
  Value: manufacturer_brand_owner > importer > first_distributor > authorised_representative · Source: https://www.verpackungsregister.org/en/first-steps/distinguishing-between-manufacturers-producers · Retrieved: November 4, 2026 · Status: verified
  Verbatim quote: 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
- <a id="a-hierarchy-secondary"></a>Germany: at the secondary packaging level the producer hierarchy names the manufacturer or brand owner, importer, first distributor and authorised representative (2026). [#a-hierarchy-secondary](#a-hierarchy-secondary)
  Value: manufacturer_brand_owner > importer > first_distributor > authorised_representative · Source: https://www.verpackungsregister.org/en/first-steps/distinguishing-between-manufacturers-producers · Retrieved: November 4, 2026 · Status: verified
  Verbatim quote: 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
- <a id="a-hierarchy-service"></a>Germany: at the service packaging level the producer hierarchy names the manufacturer or brand owner, manufacturer, importer, first distributor and authorised representative (2026). [#a-hierarchy-service](#a-hierarchy-service)
  Value: manufacturer_brand_owner > manufacturer > importer > first_distributor > authorised_representative · Source: https://www.verpackungsregister.org/en/first-steps/distinguishing-between-manufacturers-producers · Retrieved: November 4, 2026 · Status: verified
  Verbatim quote: 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
- <a id="a-hierarchy-shipping"></a>Germany: at the shipping packaging level the producer hierarchy names the manufacturer or brand owner, packer and shipper, importer, first distributor, online marketplace seller and authorised representative (2026). [#a-hierarchy-shipping](#a-hierarchy-shipping)
  Value: manufacturer_brand_owner > packer_shipper > importer > first_distributor > online_marketplace_seller > authorised_representative · Source: https://www.verpackungsregister.org/en/first-steps/distinguishing-between-manufacturers-producers · Retrieved: November 4, 2026 · Status: verified
  Verbatim quote: 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
- <a id="a-hierarchy-tertiary"></a>Germany: at the tertiary packaging level the producer hierarchy names the manufacturer or brand owner, manufacturer, importer, first distributor and authorised representative (2026). [#a-hierarchy-tertiary](#a-hierarchy-tertiary)
  Value: manufacturer_brand_owner > manufacturer > importer > first_distributor > authorised_representative · Source: https://www.verpackungsregister.org/en/first-steps/distinguishing-between-manufacturers-producers · Retrieved: November 4, 2026 · Status: verified
  Verbatim quote: 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
- <a id="a-threshold-declaration-of-completeness-glass"></a>Germany threshold on tonnage: 80 tonnes; effect: triggers a declaration of completeness. [#a-threshold-declaration-of-completeness-glass](#a-threshold-declaration-of-completeness-glass)
  Value: 80 tonnes · Source: https://www.verpackungsregister.org/en/system-participation-data-reporting/declaration-of-completeness · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Glass: 80 tonnes
- <a id="a-threshold-declaration-of-completeness-paper"></a>Germany threshold on tonnage: 50 tonnes; effect: triggers a declaration of completeness. [#a-threshold-declaration-of-completeness-paper](#a-threshold-declaration-of-completeness-paper)
  Value: 50 tonnes · Source: https://www.verpackungsregister.org/en/system-participation-data-reporting/declaration-of-completeness · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Paper, paperboard, cardboard (PPC) in total: 50 tonnes
- <a id="a-threshold-declaration-of-completeness-lightweight"></a>Germany threshold on tonnage: 30 tonnes; effect: triggers a declaration of completeness. [#a-threshold-declaration-of-completeness-lightweight](#a-threshold-declaration-of-completeness-lightweight)
  Value: 30 tonnes · Source: https://www.verpackungsregister.org/en/system-participation-data-reporting/declaration-of-completeness · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Ferrous metals + aluminium + plastics + beverage cartons + other composites (lightweight packaging) in total: 30 tonnes
- <a id="a-threshold-simplified-reporting"></a>Germany threshold on tonnage: 10 tonnes; effect: reduced duties. [#a-threshold-simplified-reporting](#a-threshold-simplified-reporting)
  Value: 10 tonnes · Source: https://www.verpackungsregister.org/en/system-participation-data-reporting/data-reporting · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: A simplified reporting requirement applies to producers who made available less than 10 tonnes of packaging subject to system participation
- <a id="a-deadline-year-end-volume-report"></a>Germany: report date June 1, 2027, covering calendar year 2026. [#a-deadline-year-end-volume-report](#a-deadline-year-end-volume-report)
  Value: June 1, 2027 · Source: https://www.verpackungsregister.org/en/system-participation-data-reporting/data-reporting · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Year-end volume reports for the previous year (actual volumes) can only be filed up to 1 June.
- <a id="a-deadline-planned-volume-report"></a>Germany: report date December 31, 2026, covering calendar year 2027. [#a-deadline-planned-volume-report](#a-deadline-planned-volume-report)
  Value: December 31, 2026 · Source: https://www.verpackungsregister.org/en/system-participation-data-reporting/data-reporting · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Initial planned volume reports for the following year can only be filed by 31 December of the current year.
- <a id="a-deadline-declaration-of-completeness"></a>Germany: report date May 15, 2027, covering calendar year 2026. [#a-deadline-declaration-of-completeness](#a-deadline-declaration-of-completeness)
  Value: May 15, 2027 · Source: https://www.verpackungsregister.org/en/system-participation-data-reporting/declaration-of-completeness · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: by no later than 15 May of any given year for the previous year.
- <a id="a-scope-materials"></a>Germany: materials covered is paper and card, glass, plastic, steel, aluminium, fibre based composite, other. [#a-scope-materials](#a-scope-materials)
  Value: paper_and_card,glass,plastic,steel,aluminium,fibre_based_composite,other · Source: https://www.verpackungsregister.org/en/registration/find-out-about-registrations · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: There are two different packaging categories: packaging subject to system participation and packaging not subject to system participation.
- <a id="a-scope-products"></a>Germany: product classes covered is primary packaging, secondary packaging, shipment packaging, tertiary packaging, reusable packaging. [#a-scope-products](#a-scope-products)
  Value: primary_packaging,secondary_packaging,shipment_packaging,tertiary_packaging,reusable_packaging · Source: https://www.verpackungsregister.org/en/registration/find-out-about-registrations · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: There are two different packaging categories: packaging subject to system participation and packaging not subject to system participation.
- <a id="a-scope-channels"></a>Germany: sales channels addressed is retail, wholesale, online, online marketplace. [#a-scope-channels](#a-scope-channels)
  Value: retail,wholesale,online,online_marketplace · Source: https://www.verpackungsregister.org/en/registration/find-out-about-registrations · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: There are two different packaging categories: packaging subject to system participation and packaging not subject to system participation.
- <a id="a-scope-ph-primary"></a>Germany: producer duty: primary packaging is manufacturer_brand_owner; importer; first_distributor; authorised_representative. [#a-scope-ph-primary](#a-scope-ph-primary)
  Value: manufacturer or brand owner, importer, first distributor, and authorized representative · Source: https://www.verpackungsregister.org/en/first-steps/distinguishing-between-manufacturers-producers · Retrieved: November 4, 2026 · Status: verified
  Verbatim quote: 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
- <a id="a-scope-ph-secondary"></a>Germany: producer duty: secondary packaging is manufacturer_brand_owner; importer; first_distributor; authorised_representative. [#a-scope-ph-secondary](#a-scope-ph-secondary)
  Value: manufacturer or brand owner, importer, first distributor, and authorized representative · Source: https://www.verpackungsregister.org/en/first-steps/distinguishing-between-manufacturers-producers · Retrieved: November 4, 2026 · Status: verified
  Verbatim quote: 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
- <a id="a-scope-ph-tertiary"></a>Germany: producer duty: tertiary packaging is manufacturer_brand_owner; manufacturer; importer; first_distributor; authorised_representative. [#a-scope-ph-tertiary](#a-scope-ph-tertiary)
  Value: manufacturer or brand owner, manufacturer, importer, first distributor, and authorized representative · Source: https://www.verpackungsregister.org/en/first-steps/distinguishing-between-manufacturers-producers · Retrieved: November 4, 2026 · Status: verified
  Verbatim quote: 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
- <a id="a-scope-ph-shipping"></a>Germany: producer duty: shipping packaging is manufacturer_brand_owner; packer_shipper; importer; first_distributor; online_marketplace_seller; authorised_representative. [#a-scope-ph-shipping](#a-scope-ph-shipping)
  Value: manufacturer or brand owner, packer or shipper, importer, first distributor, seller on an online marketplace, and authorized representative · Source: https://www.verpackungsregister.org/en/first-steps/distinguishing-between-manufacturers-producers · Retrieved: November 4, 2026 · Status: verified
  Verbatim quote: 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
- <a id="a-scope-ph-service"></a>Germany: producer duty: service packaging is manufacturer_brand_owner; manufacturer; importer; first_distributor; authorised_representative. [#a-scope-ph-service](#a-scope-ph-service)
  Value: manufacturer or brand owner, manufacturer, importer, first distributor, and authorized representative · Source: https://www.verpackungsregister.org/en/first-steps/distinguishing-between-manufacturers-producers · Retrieved: November 4, 2026 · Status: verified
  Verbatim quote: 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
- <a id="a-scope-ph-other"></a>Germany: producer duty: other packaging is manufacturer_brand_owner; manufacturer; importer; first_distributor; authorised_representative. [#a-scope-ph-other](#a-scope-ph-other)
  Value: manufacturer or brand owner, manufacturer, importer, first distributor, and authorized representative · Source: https://www.verpackungsregister.org/en/first-steps/distinguishing-between-manufacturers-producers · Retrieved: November 4, 2026 · Status: verified
  Verbatim quote: 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
- <a id="b-regime"></a>Washington: the packaging rules sit in Washington Recycling Reform Act, chapter 70A.208 RCW. [#b-regime](#b-regime)
  Value: Washington Recycling Reform Act, chapter 70A.208 RCW · Source: https://circularactionalliance.org/washington · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: required in the Recycling Reform Act
- <a id="b-regulator"></a>Washington: the regulator is Washington State Department of Ecology. [#b-regulator](#b-regulator)
  Value: Washington State Department of Ecology · Source: https://circularactionalliance.org/washington · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: By January 1, 2026 Washington Department of Ecology must establish and appoint the initial membership of the advisory council.
- <a id="b-obligated"></a>Washington places an obligation on packaging producers. [#b-obligated](#b-obligated)
  Value: yes · Source: https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true · Retrieved: November 3, 2026 · Status: verified
  Verbatim quote: After July 1, 2026, be a member of a producer responsibility organization registered in this state
- <a id="b-registration"></a>Washington: producers must register through Producer registers with a PRO; the PRO registers with Ecology. [#b-registration](#b-registration)
  Value: yes · Source: https://circularactionalliance.org/washington · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: July 1, 2026 Washington regulatory deadline for Producers to register with a PRO.
- <a id="b-organisation"></a>Washington organises producer responsibility through a single producer responsibility organisation: Circular Action Alliance; membership is required. [#b-organisation](#b-organisation)
  Value: one producer responsibility organisation · Source: https://ecology.wa.gov/waste-toxics/reducing-recycling-waste/our-recycling-programs/recycling-reform-act/producer-responsibility-organization · Retrieved: November 5, 2026 · Status: verified
  Verbatim quote: The Circular Action Alliance is the PRO representing producers in Washington. We encourage all potentially obligated producers to register with CAA.
- <a id="b-revenue-scope"></a>Washington measures revenue as worldwide gross revenue in USD, over the prior fiscal year. [#b-revenue-scope](#b-revenue-scope)
  Value: global_gross_revenue · Source: https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true · Retrieved: November 3, 2026 · Status: verified
  Verbatim quote: Has a global gross revenue, not including on-premises alcohol sales, for the prior fiscal year of
- <a id="b-hierarchy-primary"></a>Washington: at the primary packaging level the producer hierarchy names the manufacturer, brand licensee, brand owner and importer (2025). [#b-hierarchy-primary](#b-hierarchy-primary)
  Value: manufacturer > licensee > brand_owner > importer · Source: https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true · Retrieved: November 3, 2026 · Status: verified
  Verbatim quote: the producer is the person that manufactures the item
- <a id="b-threshold-de-minimis-tonnage"></a>Washington threshold on tonnage: 1 short ton; effect: exempt below the threshold. [#b-threshold-de-minimis-tonnage](#b-threshold-de-minimis-tonnage)
  Value: 1 short ton · Source: https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true · Retrieved: November 3, 2026 · Status: verified
  Verbatim quote: In their most recent fiscal year introduced less than one ton of covered materials
- <a id="b-threshold-de-minimis-revenue"></a>Washington threshold on revenue: $5,000,000; effect: exempt below the threshold. [#b-threshold-de-minimis-revenue](#b-threshold-de-minimis-revenue)
  Value: $5,000,000 · Source: https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true · Retrieved: November 3, 2026 · Status: verified
  Verbatim quote: Until January 1, 2031, less than $5,000,000
- 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. [#b-exemption-de-minimis-producer](#b-exemption-de-minimis-producer)
  Value: de_minimis_producer · Source: https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true · Retrieved: November 3, 2026 · Status: verified
  Verbatim quote: "De minimis producer" means a producer that
- 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. [#b-exemption-nonprofits](#b-exemption-nonprofits)
  Value: nonprofits · Source: https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true · Retrieved: November 3, 2026 · Status: verified
  Verbatim quote: Registered 501(c)(3) charitable organizations and 501(c)(4) social welfare organizations
- <a id="b-deadline-pro-registers-with-ecology"></a>Washington: other date March 1, 2026. [#b-deadline-pro-registers-with-ecology](#b-deadline-pro-registers-with-ecology)
  Value: March 1, 2026 · Source: https://circularactionalliance.org/washington · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: By March 1, 2026 A PRO must register with Washington Department of Ecology on behalf of its producers.
- <a id="b-deadline-simplified-report-2026"></a>Washington: report date May 31, 2026. [#b-deadline-simplified-report-2026](#b-deadline-simplified-report-2026)
  Value: May 31, 2026 · Source: https://circularactionalliance.org/washington · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: By May 31, 2026 Reporting (Interim State Addendum Signed & Simplified Reporting)
- <a id="b-deadline-producer-pro-membership"></a>Washington: registration date July 1, 2026. [#b-deadline-producer-pro-membership](#b-deadline-producer-pro-membership)
  Value: July 1, 2026 · Source: https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true · Retrieved: November 3, 2026 · Status: verified
  Verbatim quote: After July 1, 2026, be a member of a producer responsibility organization registered in this state
- <a id="b-deadline-plan-due"></a>Washington: other date October 1, 2028. [#b-deadline-plan-due](#b-deadline-plan-due)
  Value: October 1, 2028 · Source: https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true · Retrieved: November 3, 2026 · Status: verified
  Verbatim quote: By October 1, 2028, and every five years thereafter, submit a plan that meets the requirements of this chapter
- <a id="b-deadline-non-member-sales-ban"></a>Washington: other date March 1, 2029. [#b-deadline-non-member-sales-ban](#b-deadline-non-member-sales-ban)
  Value: March 1, 2029 · Source: https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true · Retrieved: November 3, 2026 · Status: verified
  Verbatim quote: Beginning March 1, 2029, a producer that is not a member in good standing with a registered producer responsibility organization
- <a id="b-deadline-program-implementation"></a>Washington: other date January 1, 2030. [#b-deadline-program-implementation](#b-deadline-program-implementation)
  Value: January 1, 2030 · Source: https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true · Retrieved: November 3, 2026 · Status: verified
  Verbatim quote: By January 1, 2030, or within six months of plan approval, whichever is later, implement the plan approved by the department
- <a id="b-deadline-net-cost-75"></a>Washington: payment date February 15, 2031. [#b-deadline-net-cost-75](#b-deadline-net-cost-75)
  Value: February 15, 2031 · Source: https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true · Retrieved: November 3, 2026 · Status: verified
  Verbatim quote: No less than 75 percent of the net costs by February 15, 2031
- <a id="b-deadline-net-cost-90"></a>Washington: payment date February 15, 2032. [#b-deadline-net-cost-90](#b-deadline-net-cost-90)
  Value: February 15, 2032 · Source: https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true · Retrieved: November 3, 2026 · Status: verified
  Verbatim quote: No less than 90 percent of the net costs by February 15, 2032, and each year thereafter
- Washington penalty for producer violating chapter 70A.208 RCW: up to $1,000 per day. [#b-penalty-0](#b-penalty-0)
  Value: $1,000 · Source: https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true · Retrieved: November 3, 2026 · Status: verified
  Verbatim quote: civil penalty of up to $1,000 per violation per day on any producer who violates this chapter
- <a id="b-scope-materials"></a>Washington: materials covered is packaging, paper products. [#b-scope-materials](#b-scope-materials)
  Value: packaging,paper_products · Source: https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true · Retrieved: November 3, 2026 · Status: verified
  Verbatim quote: "Covered material" means packaging and paper products introduced into the state.
- <a id="b-scope-products"></a>Washington: product classes covered is packaging, paper. [#b-scope-products](#b-scope-products)
  Value: packaging,paper · Source: https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true · Retrieved: November 3, 2026 · Status: verified
  Verbatim quote: "Covered material" means packaging and paper products introduced into the state.
- <a id="b-scope-excluded"></a>Washington: excluded from scope is exempt materials. [#b-scope-excluded](#b-scope-excluded)
  Value: exempt_materials · Source: https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true · Retrieved: November 3, 2026 · Status: verified
  Verbatim quote: "Covered material" means packaging and paper products introduced into the state.
- <a id="b-scope-channels"></a>Washington: sales channels addressed is physical retail, remote sale, other distribution. [#b-scope-channels](#b-scope-channels)
  Value: physical_retail,remote_sale,other_distribution · Source: https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true · Retrieved: November 3, 2026 · Status: verified
  Verbatim quote: "Covered material" means packaging and paper products introduced into the state.
- <a id="b-scope-ph-primary"></a>Washington: producer duty: primary packaging is manufacturer; licensee; brand_owner; importer. [#b-scope-ph-primary](#b-scope-ph-primary)
  Value: manufacturer, licensee, brand owner, and importer · Source: https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true · Retrieved: November 3, 2026 · Status: verified
  Verbatim quote: the producer is the person that manufactures the item
- <a id="b-scope-ex1"></a>Washington: exemption 1 is A de minimis producer is under one ton, or under the global revenue limit, or an agricultural employer within limits. [#b-scope-ex1](#b-scope-ex1)
  Value: A de minimis producer is under one ton, or under the global revenue limit, or an agricultural employer within limits. · Source: https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true · Retrieved: November 3, 2026 · Status: verified
  Verbatim quote: "De minimis producer" means a producer that
- <a id="b-scope-ex2"></a>Washington: exemption 2 is Registered 501(c)(3) and 501(c)(4) organizations are excluded from the producer definition. [#b-scope-ex2](#b-scope-ex2)
  Value: Registered 501(c)(3) and 501(c)(4) organizations are excluded from the producer definition. · Source: https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true · Retrieved: November 3, 2026 · Status: verified
  Verbatim quote: Registered 501(c)(3) charitable organizations and 501(c)(4) social welfare organizations
- Both programmes require a producer to register, in Germany and in Washington. [#calc-registration](#calc-registration)
  Value: same · Source: https://www.verpackungsregister.org/en/registration/find-out-about-registrations · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: you must register with the LUCID Packaging Register. Registering is free of charge.
- 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. [#calc-report-date](#calc-report-date)
  Value: DE days · Source: https://www.verpackungsregister.org/en/system-participation-data-reporting/declaration-of-completeness · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: by no later than 15 May of any given year for the previous 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). [#a-format-spec](#a-format-spec)
  Value: XML producer volume report with elements VersionNoInterface, PackagingTypeCode, TypeOfReportCode, ReportingPeriodFrom, ReportingPeriodTo and one SystemOperator with its SystemOperatorID and a Material list (MaterialCode, Mass). · Source: https://www.verpackungsregister.org/fileadmin/files/LUCID/Anleitung_XML_Datenmeldung_EN.pdf · Retrieved: September 30, 2026 · Status: verified
  Verbatim quote: Mass: packaging material mass in kg to the third decimal place without thousands separators (decimal place demarcated with comma).

## Related pages

### Part of

- [Germany EPR](https://instica.com/epr/germany)

### Explore packaging EPR

- [Europe extended producer responsibility packaging](https://instica.com/epr/europe)

### More for this jurisdiction

- [Washington EPR](https://instica.com/epr/washington)

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## Sources

1. verpackungsregister.org: system participation (https://www.verpackungsregister.org/en/system-participation-data-reporting/system-participation), Retrieved: September 29, 2026, Status: verified
   > you must finance the recycling of your packaging by participating that packaging in a system.
2. verpackungsregister.org: declaration of completeness (https://www.verpackungsregister.org/en/system-participation-data-reporting/declaration-of-completeness), Retrieved: September 29, 2026, Status: verified
   > The Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR) and the competent state authorities
3. verpackungsregister.org: find out about registrations (https://www.verpackungsregister.org/en/registration/find-out-about-registrations), Retrieved: September 29, 2026, Status: verified
   > If you are distributing packaged goods in Germany, you have to be registered with the LUCID Packaging Register.
4. verpackungsregister.org: find out about registrations (https://www.verpackungsregister.org/en/registration/find-out-about-registrations), Retrieved: September 29, 2026, Status: verified
   > you must register with the LUCID Packaging Register. Registering is free of charge.
5. verpackungsregister.org: system participation (https://www.verpackungsregister.org/en/system-participation-data-reporting/system-participation), Retrieved: September 29, 2026, Status: verified
   > You can conclude your system participation agreement with the system operator of your choice.
6. verpackungsregister.org: system participation (https://www.verpackungsregister.org/en/system-participation-data-reporting/system-participation), Retrieved: September 29, 2026, Status: verified
   > you are required to conclude a system participation agreement with a system operator.
7. verpackungsregister.org: distinguishing between manufacturers producers (https://www.verpackungsregister.org/en/first-steps/distinguishing-between-manufacturers-producers), Retrieved: November 4, 2026, Status: verified
   > 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
8. verpackungsregister.org: declaration of completeness (https://www.verpackungsregister.org/en/system-participation-data-reporting/declaration-of-completeness), Retrieved: September 29, 2026, Status: verified
   > Glass: 80 tonnes
9. verpackungsregister.org: declaration of completeness (https://www.verpackungsregister.org/en/system-participation-data-reporting/declaration-of-completeness), Retrieved: September 29, 2026, Status: verified
   > Paper, paperboard, cardboard (PPC) in total: 50 tonnes
10. verpackungsregister.org: declaration of completeness (https://www.verpackungsregister.org/en/system-participation-data-reporting/declaration-of-completeness), Retrieved: September 29, 2026, Status: verified
   > Ferrous metals + aluminium + plastics + beverage cartons + other composites (lightweight packaging) in total: 30 tonnes
11. verpackungsregister.org: data reporting (https://www.verpackungsregister.org/en/system-participation-data-reporting/data-reporting), Retrieved: September 29, 2026, Status: verified
   > A simplified reporting requirement applies to producers who made available less than 10 tonnes of packaging subject to system participation
12. verpackungsregister.org: data reporting (https://www.verpackungsregister.org/en/system-participation-data-reporting/data-reporting), Retrieved: September 29, 2026, Status: verified
   > Year-end volume reports for the previous year (actual volumes) can only be filed up to 1 June.
13. verpackungsregister.org: data reporting (https://www.verpackungsregister.org/en/system-participation-data-reporting/data-reporting), Retrieved: September 29, 2026, Status: verified
   > Initial planned volume reports for the following year can only be filed by 31 December of the current year.
14. verpackungsregister.org: declaration of completeness (https://www.verpackungsregister.org/en/system-participation-data-reporting/declaration-of-completeness), Retrieved: September 29, 2026, Status: verified
   > by no later than 15 May of any given year for the previous year.
15. verpackungsregister.org: find out about registrations (https://www.verpackungsregister.org/en/registration/find-out-about-registrations), Retrieved: September 29, 2026, Status: verified
   > There are two different packaging categories: packaging subject to system participation and packaging not subject to system participation.
16. circularactionalliance.org: washington (https://circularactionalliance.org/washington), Retrieved: September 29, 2026, Status: verified
   > required in the Recycling Reform Act
17. circularactionalliance.org: washington (https://circularactionalliance.org/washington), Retrieved: September 29, 2026, Status: verified
   > By January 1, 2026 Washington Department of Ecology must establish and appoint the initial membership of the advisory council.
18. app.leg.wa.gov: default (https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true), Retrieved: November 3, 2026, Status: verified
   > After July 1, 2026, be a member of a producer responsibility organization registered in this state
19. circularactionalliance.org: washington (https://circularactionalliance.org/washington), Retrieved: September 29, 2026, Status: verified
   > July 1, 2026 Washington regulatory deadline for Producers to register with a PRO.
20. ecology.wa.gov: producer responsibility organization (https://ecology.wa.gov/waste-toxics/reducing-recycling-waste/our-recycling-programs/recycling-reform-act/producer-responsibility-organization), Retrieved: November 5, 2026, Status: verified
   > The Circular Action Alliance is the PRO representing producers in Washington. We encourage all potentially obligated producers to register with CAA.
21. app.leg.wa.gov: default (https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true), Retrieved: November 3, 2026, Status: verified
   > Has a global gross revenue, not including on-premises alcohol sales, for the prior fiscal year of
22. app.leg.wa.gov: default (https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true), Retrieved: November 3, 2026, Status: verified
   > the producer is the person that manufactures the item
23. app.leg.wa.gov: default (https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true), Retrieved: November 3, 2026, Status: verified
   > In their most recent fiscal year introduced less than one ton of covered materials
24. app.leg.wa.gov: default (https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true), Retrieved: November 3, 2026, Status: verified
   > Until January 1, 2031, less than $5,000,000
25. app.leg.wa.gov: default (https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true), Retrieved: November 3, 2026, Status: verified
   > "De minimis producer" means a producer that
26. app.leg.wa.gov: default (https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true), Retrieved: November 3, 2026, Status: verified
   > Registered 501(c)(3) charitable organizations and 501(c)(4) social welfare organizations
27. circularactionalliance.org: washington (https://circularactionalliance.org/washington), Retrieved: September 29, 2026, Status: verified
   > By March 1, 2026 A PRO must register with Washington Department of Ecology on behalf of its producers.
28. circularactionalliance.org: washington (https://circularactionalliance.org/washington), Retrieved: September 29, 2026, Status: verified
   > By May 31, 2026 Reporting (Interim State Addendum Signed & Simplified Reporting)
29. app.leg.wa.gov: default (https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true), Retrieved: November 3, 2026, Status: verified
   > By October 1, 2028, and every five years thereafter, submit a plan that meets the requirements of this chapter
30. app.leg.wa.gov: default (https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true), Retrieved: November 3, 2026, Status: verified
   > Beginning March 1, 2029, a producer that is not a member in good standing with a registered producer responsibility organization
31. app.leg.wa.gov: default (https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true), Retrieved: November 3, 2026, Status: verified
   > By January 1, 2030, or within six months of plan approval, whichever is later, implement the plan approved by the department
32. app.leg.wa.gov: default (https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true), Retrieved: November 3, 2026, Status: verified
   > No less than 75 percent of the net costs by February 15, 2031
33. app.leg.wa.gov: default (https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true), Retrieved: November 3, 2026, Status: verified
   > No less than 90 percent of the net costs by February 15, 2032, and each year thereafter
34. app.leg.wa.gov: default (https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true), Retrieved: November 3, 2026, Status: verified
   > civil penalty of up to $1,000 per violation per day on any producer who violates this chapter
35. app.leg.wa.gov: default (https://app.leg.wa.gov/RCW/default.aspx?cite=70A.208&full=true), Retrieved: November 3, 2026, Status: verified
   > "Covered material" means packaging and paper products introduced into the state.
36. verpackungsregister.org: Anleitung XML Datenmeldung EN (https://www.verpackungsregister.org/fileadmin/files/LUCID/Anleitung_XML_Datenmeldung_EN.pdf), Retrieved: September 30, 2026, Status: verified
   > Mass: packaging material mass in kg to the third decimal place without thousands separators (decimal place demarcated with comma).

## Cite this page

Instica, “Germany vs Washington EPR: Rules Compared”, https://instica.com/epr/compare/germany-vs-washington, last verified 2026-11-05, dataset v1-281284b7e7c1, CC-BY-4.0.

- Canonical URL: https://instica.com/epr/compare/germany-vs-washington
- Last verified: November 5, 2026
- Last changed: November 5, 2026
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