On 11 February 2026 in Berlin, the Federal Cabinet adopted the draft Packaging Law Implementation Act (VerpackDG). The new law is designed to transpose the EU Packaging and Packaging Waste Regulation (PPWR) into German law and will replace the existing Packaging Act (VerpackG). The goal is to ensure smooth interaction with the EU framework from August 2026 while maintaining and further developing Germany’s established packaging compliance structures.
Table of Contents
Alignment with the EU Packaging Regulation
The new VerpackDG serves as the national implementation of the European Packaging Regulation. While the EU regulation applies directly, certain elements require national rules, particularly around enforcement, authorisation and financing structures.
Germany is choosing evolution over disruption. Existing mechanisms, such as the Central Agency Packaging Register (ZSVR) will remain in place, but with expanded responsibilities and tighter oversight.
Expanded Authorisation Requirements
One of the most significant changes concerns authorisation. Until now, authorisation primarily applied to dual systems responsible for the collection of household packaging waste via the yellow bin or yellow bag. Under the new law, this requirement will be extended. In future:
- All organisations assuming extended producer responsibility (EPR) for multiple producers must obtain approval.
- Manufacturers that do not join such an organisation will need to apply for individual authorisation.
An automated, low-bureaucracy procedure is planned via the ZSVR. Importantly, the financing of the system will also change. New participants brought under the authorisation framework will contribute to funding, whereas until now financing was largely borne by dual systems and industry solution operators.
For packaging producers, this means closer scrutiny of how and through whom their EPR obligations are fulfilled.
Mandatory Waste Prevention Measures
Waste prevention is no longer a soft policy goal, but a funded obligation. Under the draft law, certain actors, including dual systems, industry solutions, other EPR organisations and even producers not represented by such organisations, must allocate a minimum share of their budgets to waste prevention measures.
Planned measures include:
- Financial support for reusable packaging systems
- Promotion of refill solutions
- Public information campaigns encouraging reuse
The intention is to reduce single-use packaging volumes and accelerate the shift toward circular models. For companies investing in reuse infrastructure, this could open new funding and partnership opportunities.
Higher Recycling Targets from 2028
The VerpackDG also tightens recycling quotas, with new targets taking effect from 2028. Key changes include:
- Aluminium and ferrous metals: recycling rates will increase by 5 percentage points, to 95 % each.
- Plastics: The previous recovery rate will be replaced by a 75 % recycling rate. Of this, 70 % must be materially recycled. The remaining share may be achieved through other recognised recycling processes.
What Happens Next?
Following the cabinet decision, the draft law will undergo notification at the European level. It must then pass through the Bundestag, with the Bundesrat also involved in the legislative process.
If adopted as planned, the new framework will apply alongside the EU Packaging Regulation from August 2026.
Conclusion
The Packaging Law Implementation Act signals a more structured and demanding phase for the German packaging market. By expanding authorisation requirements, mandating financial commitments to waste prevention and raising recycling quotas, the German government is tightening both compliance oversight and circular economy performance standards. Companies operating in Germany should use the transition period to review their EPR arrangements, authorisation status and long-term material strategies, as regulatory alignment with the EU framework will soon move from preparation to enforcement.
