The short answer is: the PPWR itself does not specify any specific fine amounts. However, it obliges EU Member States to introduce effective, proportionate and dissuasive sanctions. In Germany, this will be implemented through the VerpackDG in the future.
What sanctions does the PPWR provide for?
The provisions on sanctions in the EU Packaging Regulation are set out in Article 68 of the PPWR. Unlike many national laws, the regulation does not specify specific fines. Instead, it requires all Member States to establish and enforce national sanction regimes.
Importantly, the PPWR expressly requires administrative fines for breaches of key conformity provisions. These include requirements concerning packaging conformity, the EU Declaration of Conformity, technical documentation, conformity assessment procedures, CE marking, and the obligations of producers, importers and other economic operators.
Member States may also impose penalties for breaches of other PPWR requirements, including those relating to packaging recyclability, minimum recycled content, labelling and information, reuse, material restrictions and specific packaging formats. The applicable fines depend on the respective national law.
The European Commission has, in its new FAQ catalogue dated 31 July 2026, provided an important clarification on enforcement of the PPWR requirements applicable from 12 August 2026.
The Commission emphasises that enforcement should not disrupt trade, supply chains or consumers’ access to goods. Referring to Article 62 of the PPWR, it explains that where infringements are identified, the competent authorities should first require the economic operator to remedy the non-compliance. Companies should therefore receive a warning and the opportunity to take appropriate corrective measures.
The Commission also makes clear that market surveillance authorities should not focus primarily on sanctions, particularly during the initial phase. Instead, they should support companies in implementing the new requirements through measures such as:
- awareness-raising and information campaigns,
- requests for information,
- requests to implement corrective measures,
- as well as appropriate transition and adaptation periods.
What penalties does the VerpackDG provide for?
When the VerpackDG comes into force on 12 August 2026, the existing penalty provisions of the Packaging Act will be incorporated into the new Implementing Act and adapted to the PPWR. In principle, existing fines will remain in place, while new grounds for fines will be introduced to cover the additional PPWR obligations.
Depending on the nature and severity of the infringement, companies can face fines of up to €200,000.
The highest fines are particularly likely where packaging subject to system participation requirements is placed on the market without proper participation or is sold despite a statutory distribution ban.
Fines of up to €100,000 may apply, among other things, to breaches of registration and reporting obligations, failure to provide evidence, or breaches of take-back and deposit obligations. Certain formal breaches may result in fines of up to €10,000.
As the VerpackDG implements the PPWR in German law, it can be expected that breaches of new documentation, conformity and labelling obligations will also be subject to fines.
Which new PPWR obligations will be subject to sanctions in future?
The PPWR introduces numerous new obligations for producers, importers and other economic operators. Many of these did not previously exist under German packaging law. The most important include:
- drawing up an EU Declaration of Conformity for packaging,
- drawing up and making technical documentation available,
- carrying out a conformity assessment procedure,
- affixing the prescribed markings,
- complying with recyclability requirements,
- complying with minimum recycled content requirements,
- implementing the new labelling and information obligations,
- complying with the requirements for reusable packaging, and
- meeting other product-specific requirements of the PPWR.
For key compliance obligations, the PPWR expressly requires Member States to provide for administrative fines. Companies should therefore expect breaches of these new requirements to be pursued as rigorously as breaches of registration or system participation obligations.
Fines are not the only consequence
In addition to fines, the Packaging Law Implementation Act (VerpackDG) provides for further measures. For example, breaches of registration or scheme participation obligations may result in packaging no longer being permitted to be placed on the market or sold. For many companies, a sales ban could be economically far more serious than the fine itself.
Registrations also remain accessible in the public register. Breaches can therefore be identified not only by enforcement authorities but also by competitors, business partners or online marketplaces. In practice, this may lead to additional warnings under competition law or injunctions.
Depending on the individual case, further regulatory measures – including the confiscation of the packaging concerned or other items – may also be considered.
Conclusion: The PPWR also increases the risk of sanctions
With the implementation of the PPWR and the simultaneous entry into force of the VerpackDG, European packaging law is undergoing fundamental change. While the PPWR harmonises substantive packaging requirements across Europe, the VerpackDG provides the framework for their enforcement in Germany.
For businesses, this means not only new documentation, compliance and labelling obligations, but also an increased risk of significant penalties. Companies that fail to implement the new requirements in good time may face fines, sales bans and further regulatory measures.
