On 17 July 2026, Germany’s new Packaging Law Implementation Act (Verpackungsrecht-Durchführungsgesetz, VerpackDG) was published in the Federal Law Gazette, replacing the previous Packaging Act (VerpackG). The VerpackDG entered into force on 12 August 2026, the same day that the PPWR became applicable across all EU Member States.
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An important distinction: the PPWR is directly applicable in Germany and does not require transposition into national law. The VerpackDG does not transpose the PPWR. Instead, it fills the gaps where the PPWR either requires national implementation or leaves room for national discretion – responsibilities, enforcement, sanctions and the continuation of existing German waste management structures.
What Stays the Same
The German government prioritized continuity. Several structures that the packaging industry in Germany has operated under for years have been carried over into the new law.
The dual system for collecting and recovering packaging waste remains in place. Private system operators continue to organize the nationwide collection of packaging through the yellow bag or bin system on behalf of producers. Under the VerpackDG, they are now formally classified as producer responsibility organizations within the meaning of the PPWR, but the operational model is unchanged.
The licensing requirement, a Germany-specific obligation, also continues. Packaging that typically ends up as waste in private households or comparable establishments such as restaurants and hotels must still be licensed through a system operator before it can be placed on the German market. The distinction between packaging requiring licensing and B2B packaging that does not, remains the defining structural feature of German packaging law.
The Central Agency Packaging Register (ZSVR) retains its existing responsibilities, including managing the LUCID packaging register. Producers already registered under the previous Packaging Act are automatically deemed registered under the new law, though they must notify the authorities of any necessary changes.
The single-use deposit of €0.25, the reuse target of at least 70 % for beverages, the collection thresholds for single-use plastic beverage bottles (77 %, rising to 90 % from 2029) and the minimum recycled content requirements for PET bottles (25 % since January 2025, 30 % from January 2030) all remain in place.
What Changes
The most significant change is the expansion of authorization requirements.
Under the previous law, only system operators (the private companies that manage the collection and recovery of household packaging waste through the yellow bag or bin system) needed formal authorization to participate in the dual system. The VerpackDG extends this to producers of packaging not requiring licensing, for example companies placing transport pallets or stretch film on the German market. These producers must now register with the ZSVR and either obtain authorization for their own return and recovery system or transfer their producer responsibility to an authorized organization. Producers who choose the latter option are exempt from the authorization requirement themselves.
The transitional periods are staggered: other producer responsibility organizations must be authorized by 1 November 2027 and producers of non-licensing packaging must have authorization by 1 January 2028. Existing system operators must demonstrate compliance with additional requirements by 1 January 2027.
Recycling rates for plastics have been raised and redefined. The key change is that energy recovery through incineration can no longer be counted toward the recycling rate. The new targets require at least 70 % mechanical recycling from 2028, rising to 75 % from 2030.
The VerpackDG also introduces the enforcement framework for the PPWR’s directly applicable requirements (sustainability, recyclability and labelling obligations) with fines of up to €200,000 for non-compliance. However, a transitional provision delays the application of these penalties until 12 February 2027, giving businesses a six-month grace period.
What this Means for Companies Operating in Germany
For companies already registered under the previous Packaging Act, the immediate impact is limited. Registration carries over automatically, the dual system continues to function and the licensing requirement is unchanged.
The most urgent action items are for producers of B2B packaging that was previously not subject to system participation. These producers now face a new authorization requirement with concrete deadlines in 2027 and 2028. Companies in this category should assess whether to apply for authorization themselves or transfer responsibility to an authorized organization.
For all producers placing packaging on the German market, the VerpackDG reinforces the PPWR’s conformity assessment requirements. The Declaration of Conformity may be issued in German or English. Market surveillance is delegated to the authorities of the individual German federal states and the Federal Institute for Occupational Safety and Health (BAuA) is responsible for notifying the EU Commission and other Member States in cases of non-compliance.
Conclusion
Germany’s VerpackDG is the first major national implementation framework for the PPWR and sets a precedent for how other Member States may approach the same task. Its emphasis on continuity – retaining the dual system, the licensing requirement, the ZSVR and the deposit regime – is designed to minimize disruption for producers already operating in the German market. Companies active in Germany should verify their registration status, assess the new authorization requirements and prepare for the PPWR conformity assessment obligations, keeping in mind the six-month grace period for penalties that runs until February 2027.
