Implementation of the EU Packaging Regulation (PPWR) in Germany

On November 17, 2025, the Federal Ministry for the Environment, Climate Protection, 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 adapted to the requirements of the EU Packaging Regulation (Regulation (EU) 2025/40, Packaging and Packaging Waste Regulation – PPWR), which will apply from August 12, 2026. This article provides an overview of the background and key changes in packaging law. Background to the PPWR: The PPWR has been in force since February 11, 2025. It aims in particular to strengthen the circular economy and is a key component of the EU Green Deal. While not new, the PPWR is considerably more concrete than previous regulations and includes, among other things, framework guidelines for minimizing unnecessary packaging, switching to reuse systems, increasing recyclability, and using a minimum recycled content in packaging. At the same time, labeling requirements are increasing. Based on the PPWR, numerous more detailed legal acts are expected from the European Commission between 2026 and 2040. The PPWR imposes sometimes far-reaching obligations on various economic operators, particularly "producers," "importers," and "distributors." Producers include not only those who manufacture or have packaging manufactured, but also those who manufacture or have packaged products manufactured. Each of the aforementioned economic operators can also simultaneously be a "manufacturer" within the meaning of the PPWR and thus be subject to extended producer responsibility. What is new is that significantly more companies fall under the definition of "manufacturer" under the PPWR than under the previously applicable German Packaging Act (VerpackG). It remains unchanged that the specific details of manufacturers' obligations are left to the member states. This is where the draft bill for the new Packaging Implementation Act (VerpackDG-E) comes in. Implementation in Germany and Adaptation of Packaging Law: The draft Packaging Implementation Act (VerpackDG-E) makes it clear that the existing Packaging Act (VerpackG) is to remain essentially in force; however, it introduces important changes: According to the draft Packaging Implementation Act (VerpackDG-E), there will no longer be a registration requirement only for certain systems, but also for manufacturers. Accordingly, all manufacturers and systems will have to be registered by the Central Agency in the future. It can be assumed that the register will continue to be the LUCID packaging register. An automated registration process is to be established for this purpose. Approved manufacturers and systems are then also obligated to contribute to the financing of the Central Agency. To implement the 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 January 1, 2027, systems are to pay the Central Agency five euros per ton of packaging used in the respective calculation period. Furthermore, higher recycling quotas than currently stipulated in the Packaging Act are planned. Systems will be required to meet stricter recycling quotas in the future, such as 80% for liquid cartons, 90% for glass, paper, cardboard, and carton, and from 2028, 75% for plastics (then 80% from 2030). For aluminum and ferrous metals, the required quota will even be 95% from 2028. What's also new is that, from 2028 onwards, the quota for plastics no longer has to be met solely through mechanical recycling. Instead, recycled content from chemical recycling can also be counted. German packaging law will be applicable alongside the PPWR from August 12, 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 for reusability and void formats apply beyond the national regulations and must be observed. The requirements are only partially new in light of Section 4 of the Packaging Act (VerpackG), 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 fines). Next Steps: The draft bill has not yet been finalized; it is currently undergoing inter-ministerial review within the Federal Government. Substantive changes are therefore still to be expected during the further legislative process. Comments on the draft bill can be submitted until December 5, 2025, at 11:00 p.m. Companies should also check whether they are affected by the PPWR and establish processes early on to ensure compliance with the regulation from August 2026.