The former Packaging Act (VerpackG) will be replaced by the Packaging Law Implementation Act (VerpackDG) and adapted to European structures, starting 12 August 2026.
The PPWR is intended to establish standardized packaging regulations throughout the European Union. These requirements are directly applicable to all Member States, however, certain aspects, such as specific responsibilities, registration obligations, sanction mechanisms, and enforcement measures, may be delineated at the national level. Though the basic concept of Extended Producer Responsibility will largely remain unchanged, some elements will be updated in accordance with EU law – ideally, with minimal additional bureaucracy. To this effect, dual systems, deposit obligations and the role of the German Central Agency for Packaging Registers (ZSVR: Zentrale Stelle Verpackungsregister) will be restructured.
Retailers and producers should now prepare for three significant changes brought on by the newly adopted Packaging Law Implementation Act (VerpackDG) and adapt to them by mid-2026. Overall, the new regulation calls for reducing packaging waste and promoting recyclable solutions. The goal is to lower the total volume of packaging by at least ten per cent by 2035.
Find out now which requirements actually affect you and what measures you need to take – trade-e-bility offers comprehensive schooling events covering all aspects of the Packaging Law Implementation Act to prepare you for upcoming responsibilities.
Licensing requirements are being expanded
Previously, only dual systems (such as yellow bags/bins) were subject to licensing. Going forward, producers of commercial packaging, their waste management organizations and Extended Producer Responsibility (EPR) organisations with individual obligations will also be required to register with the German Central Agency for Packaging Register (ZSVR). The approval process is expected to be largely automated. As a result, the ZSVR will no longer be supported solely by dual system operators and industry solution providers but will be co-financed by other players.
Producers are to take measures to prevent waste
In future, producers and other Extended Producer Responsibility organisations will be required to take measures to minimise waste. These include:
- Promotion of reusable packaging
- Strengthening of refill systems
- Start-up financing for new reusable systems
- Education on the use of reusable packaging
The original plan to implement a levy of five euros per tonne of packaging (estimated at 90 million euros per year) was ultimately scrapped after massive criticism from various trade associations.
Higher recycling rates to be achieved from 2028
To use resources more effectively in the future, national recycling rates are to be increased: from 2028 onwards, plastic waste will be subject to a recycling rate of 75 per cent, whereas 70 per cent of this must be recycled mechanically. There will also be greater market opportunities for chemical recycling as well. Aluminium and ferrous metals will each be recycled at a 95 per cent rate. Incineration for energy recovery will be gradually phased out.
Further requirements set by the draft bill
EU-wide harmonised labelling aims to improve sorting and waste management. Additionally, stricter rules regulating packaging design and consumer information will come into effect. Updated design provisions will limit oversized packaging and discourage hard-to-recycle plastics. Hazardous and toxic substances like per- and polyfluoroalkyl substances (PFAS) should be elided. These changes will also affect responsibilities related to material flow management, plant technology, and verification for organizations involved in waste management, recycling, and those operating sorting and processing plants.
The draft bill will not extend the dual systems' collection obligation to public spaces. However, enhanced incompatibility regulations will impose stricter requirements for expert consultants. The cabinet decision will be followed by notification under European law, afterwards, the German Bundestag and Bundesrat (parliament and council) will debate the bill.
Overall assessment
The draft Packaging Law Implementation Act has been met with a fair amount of criticism, offered by the Environmental Action Germany (DUH: Deutsche Umwelthilfe e.V.), NABU (Naturschutzbund Deutschland: German Nature And Biodiversity Conservation Union), WWF, the Federal Association for Sustainable Economy (BNW: Bundesverband Nachhaltige Wirtschaft) and also some local authorities. Particularly, criticism is directed at the insufficient structural and financial incentives to promote reusable packaging, waste prevention and recycling. The unsustainable conceptualisation of licensing costs, the funding mechanisms and potential prepayments, especially for local authorities, are also grimly judged. Seeing as there is no central control mechanism for recyclable packaging, there is still considerable room for improvement. Our VERE members will receive further information on the various positions of the associations and other stakeholders in the next ‘VERE Insider’.
Overall, the VerpackDG brings about profound structural changes for producer responsibility in Germany. Approval requirements are being expanded, recycling quotas are increased and packaging design will be stricter. Whether reusable packaging will be substantially strengthened and whether an efficient ecological steering effect can be achieved remains to be seen. However, it seems certain that producers will have to bear considerable financial, organisational and administrative costs as part of their product responsibility.
Would you like to know more about packaging law and engage in professional discourse with fellow retailers?
In light of the imminent application of the central requirements of the PPWR from 12 August 2026, we recommend that you prepare in good time. If you are looking for individual PPWR training that is specifically designed to fit your company’s needs – we suggest you request your personal online PPWR training course now.
If you have any questions about the EU Packaging Regulation, trade-e-bility will be happy to assist you via +49/40/750687-300 or sales@trade-e-bility.de.
