On 11 February 2026, the German Federal Cabinet approved the draft of the new German packaging law (VerpackDG). The new law is set to replace the existing Packaging Act (VerpackG) and will legally implement the provisions of the EU Packaging and Packaging Waste Regulation (PPWR / Regulation (EU) 2025/40) in Germany from 12 August 2026, while also addressing national regulatory gaps.
The PPWR is a directly applicable EU regulation aimed at harmonizing packaging requirements across the internal market. It establishes binding targets for reducing packaging waste, promoting recyclability and reuse, increasing recycled content, and introducing digital labeling of packaging. The regulation entered into force on 11 February 2025 and will become fully applicable with a transitional period from 12 August 2026. Previous newsletters have provided detailed coverage of these developments.
Key Points from the packaging law (11 February 2026)
- Replacement of the German packaging law: From 12 August 2026, the national Packaging law will be replaced by the new Packaging Implementation Act to integrate EU requirements legally and align them with established German procedures.
- Expanded Approval Obligations: In addition to dual systems manufacturers of commercial packaging and organizations responsible for extended producer responsibility will now be required to obtain approval from the Central Packaging Register (ZSVR).
- Waste Prevention & Recycling Targets: EU-wide and national measures to reduce packaging waste will be strengthened, and higher recycling targets will apply — e.g., 75% recycling for plastics by 2028.
- Practical Requirements: Retailers and manufacturers must prepare for stricter obligations regarding labeling, registration, and documentation.
Outlook and Criticism
The reform is considered one of the most significant steps in modernizing Germany’s packaging law and offers opportunities to strengthen the circular economy. At the same time, several critical issues remain:
- Legal Certainty: National deviations, especially the German definition of “material recycling,” differ from EU standards, making uniform implementation more challenging. Companies must navigate both national and European requirements simultaneously.
- Incentives for Eco-Friendly Design: Ecologically oriented license fees or stronger rewards for highly recyclable, non-fossil packaging are not included in the draft, leaving opportunities to incentivize sustainable packaging unexploited.
- Costs and Bureaucracy: While annual additional costs for companies have been reduced to €2.5 million and one-time transition costs amount to €4.5 million, the law introduces further documentation and organizational obligations. Efficient implementation will therefore be crucial.
The reform is currently undergoing parliamentary approval in the Bundestag and Bundesrat. Whether adjustments will be made, particularly regarding ecological incentives and alignment with EU requirements, remains to be seen.
For questions, please contact the Go4Recycling team at any time.