Implementation of the EU Packaging and Packaging Waste Regulation (PPWR) in Germany

On 17 November 2025, the German Federal Ministry for the Environment, Climate Action, Nature Conservation and Nuclear Safety (BMUKN) presented the draft bill for the new Packaging Law Implementation Act (VerpackDG-E). The current Packaging Act (VerpackG) is to be adjusted to align with the requirements of the EU Packaging and Packaging Waste Regulation (Regulation (EU) 2025/40, PPWR), which will apply from 12 August 2026. This article provides an overview of the background and key changes in packaging legislation.

Background on the PPWR

The PPWR has been in force since 11 February 2025. It aims to strengthen the circular economy and is a central part of the EU Green Deal. Amongst other things, it includes – more specific than previous regulations - framework requirements for minimizing unnecessary packaging, switching to reuse systems, increasing recyclability, and mandating minimum recycled content in packaging. At the same time, labeling requirements are increasing. Based on the PPWR, the European Commission is expected to issue numerous specific delegated and implementing acts between 2026 and 2040.

The PPWR imposes far-reaching obligations on various economic operators, especially on ‘manufacturers’, importers’, and ‘distributors’. A manufacturer is not only defined as a person who manufactures packaging or has it manufactured, but also as anyone who manufactures packaged products or has them manufactured.

Each of these economic operators may at the same time also qualify as a “producer” in the sense of the PPWR and thus be subject to extended producer responsibility. A key novelty is that significantly more companies will fall under the definition of “producer” than under the previously applicable VerpackG. What remains unchanged is that Member States still determine how these producer's obligations are implemented—this is where the draft bill for the new VerpackDG comes in.

Implementation in Germany & Adjustments to Packaging Law

The draft of the VerpackDG shows that the VerpackG currently in force is to remain largely unchanged; however, it does provide for some important new features:

• According to the VerpackDG-E, approval will no longer be required only for certain systems, but also for producers. This means that in future, all producers and systems will have to be approved by the ‘Zentrale Stelle’ (Central Agency). It can be assumed that the register will continue to be the LUCID packaging register. An automated approval process is to be set up for this purpose. Approved producers and systems will then also be obliged to contribute to the financing of the Central Agency.

• To implement PPWR requirements for waste reduction and prevention, the draft bill also provides for participation in the financing of the organization of reduction and prevention measures. From 1 January 2027, systems will be required to pay a fee of five euros per ton of packaging involved in the respective calculation period to the Central Agency.

• Furthermore, higher recycling rates than previously stipulated in the VerpackG are planned. In the future, systems will have to meet stricter recycling quotas, such as 80% for liquid packaging cartons, 90% for glass, paper, cardboard, and paperboard, and 75% for plastics from 2028 (rising to 80% from 2030). For aluminum and ferrous metals, the required quota will even be 95% from 2028. Another new feature is that, from 2028, the rate for plastics will no longer have to be achieved exclusively through material recycling. Instead, recycling rates from chemical recycling can also be taken into account.

German packaging law will apply alongside the PPWR from 12 August 2026. This means that the packaging requirements of Articles 5-12 PPWR (e.g., on minimizing packaging, recyclability, and recycled content) as well as the additional requirements on reusability and empty space ratio apply beyond the national provisions and must be considered. In light of Section 4 of the VerpackG, the requirements are only partially new but should be taken seriously in the future given the legal consequences of non-compliance with the PPWR (prohibition of placing on the market and threats of administrative fines).

Next Steps

The draft bill has not yet been finalized and is currently being coordinated within the federal government. Changes to the content are therefore still to be expected during the further legislative process. Comments on the draft bill can be submitted until 5 December 2025, at 11:00 p.m. Companies should check whether they are affected by the PPWR and set up processes at an early stage to ensure compliance with the regulation from August 2026 onwards.