In August 2026, the new provisions of the EU Packaging Regulation (PPWR) will come into force across the EU. To ensure that these Europe-wide requirements harmonise seamlessly with German law, the German government plans to replace the current Packaging Act (VerpackG) with a new Packaging Law Implementation Act (VerpackDG). The aim is to secure and optimise the structures that have developed in Germany, as reported by the Federal Ministry for the Environment (BMUKN).
In future, anyone who places packaging on the market will be required to make a financial contribution towards packaging avoidance. This is provided for in the draft bill submitted on 17 November 2025 by the Federal Environment Ministry to the federal states and associations for consultation. The draft bill on the Packaging Law Implementation Act (VerpackDG) also contains higher recycling quotas. Producers of commercial packaging and organisations that assume extended producer responsibility for several producers will require a licence in future.
Press reports describe this as the biggest reform of German packaging law in 35 years. According to Euwid, the draft bill represents the "most comprehensive reorganisation of German packaging law since the introduction of extended producer responsibility in the early 1990s". Here is a summary of the key aspects (the draft bill is 177 pages long):
FAQ on the new Packaging Act (draft bill on the Packaging Law Implementation Act – VerpackDG)
What is the aim of the draft bill on the Packaging Law Implementation Act (VerpackDG)?
The draft bill on the Packaging Law Implementation Act (VerpackDG) aims to modernise packaging waste policy in Germany. The key points are improving waste prevention, increasing recycling rates and strengthening producer responsibility. Producers who place packaging on the market will in future be held more accountable, both financially and organisationally.
Who will be required to obtain a licence in future?
The draft bill stipulates that organisations that assume extended producer responsibility for several producers, as well as producers not represented by these organisations, will require official approval in future. The aim is to achieve greater transparency and better control of waste disposal structures. According to the BMUKN, approval will be granted by the Foundation Central Agency Packaging Register (ZSVR), which must also be co-financed by these players. Until now, the ZSVR has been financed exclusively by the dual systems and operators of industry solutions. That is why there are supplementary regulations for financing the ZSVR.
What financial contributions are planned?
Dual systems, industry solutions and other organisations for producer responsibility, as well as producers not represented by these organisations, will in future pay €5 per ton of packaging provided to a joint organisation. These funds will be used to promote reusable systems, refilling, waste prevention measures and other projects to strengthen the circular economy. According to a report by Euwid, this will result in ongoing compliance costs of around €89.6 million for the economy. The money will go to the joint organisation, which will then pass it on.
How will recycling rates change?
The draft bill for the VerpackDG increases several rates:
- Metals (aluminium, iron): 95%
- Plastics: 75% from 2028, at least 70% of which must be materially recycled
These adjustments are intended to ensure that more packaging material is actually recycled and less is thermally treated.
What is the timetable?
The consultation process with the federal states and associations will run until 5 December 2025.
The draft is expected to be passed by the Federal Cabinet in the first quarter of 2026.
The parliamentary process in the Bundestag and Bundesrat will then begin. From 320 Grad's point of view, this timetable for the project is very ambitious.
What does this mean for sellers and distributors?
Several new obligations arise for sellers and other distributors of packaging:
- Financial contribution to packaging avoidance
- Compliance with higher recycling rates when purchasing goods and in the supply chain
- Review of approval requirements when packaging is involved
- Extended producer responsibility
Questions about the Packaging Act? The take-e-way consulting team is available to assist you via +49/40/750687-0 or send us an email.
Do you require personalised PPWR training tailored to your company? Due to the high level of interest in the PPWR, we recommend that you enquire about your personal online PPWR training in good time and without obligation.
