On 12 August 2026, the new Packaging Law Implementation Act (VerpackDG) will come into force at the same time as the EU Packaging Regulation (Regulation (EU) 2025/40, ‘PPWR’). It completely replaces the previous Packaging Act and is intended to ensure the application of the PPWR in Germany. The Act was published in the Federal Law Gazette on 17 July 2026.
Whilst the PPWR harmonises the substantive requirements for packaging across Europe, the VerpackDG regulates those areas necessary for the implementation of the PPWR or where the Regulation allows for national discretion.
Among other things, the Act contains provisions on the supply of packaging, authorisation, take-back and recovery, beverage packaging, the Central Packaging Register and the prevention of packaging waste.
The PPWR itself does not contain any provisions on administrative fines; however, in Article 68, it obliges Member States to provide for effective, proportionate and dissuasive sanctions. The VerpackDG fulfils this requirement with an independent system of administrative fines. Section 66 of the VerpackDG sets out offences subject to fines for breaches of both the VerpackDG itself and the PPWR, categorised according to a list of specifically named offences (Section 66(3) VerpackDG) with penalty ranges of up to 200,000 euros, 100,000 euros and 10,000 euros respectively. The offences subject to fines for direct breaches of the PPWR (breaches under Section 66(2) of the VerpackDG) will only apply from 12 February 2027.
There is therefore a limited grace period for direct PPWR infringements to allow processes to be fully adapted to the new legal situation. By contrast, the offences subject to fines for breaches of the VerpackDG itself (Section 66(1) of the VerpackDG) will apply from 12 August 2026.
The VerpackDG essentially maintains the established national deposit and return schemes for single-use beverage packaging, as well as the requirements regarding the minimum recycled content in single-use plastic beverage bottles, until the European Commission presents uniform EU-wide requirements for the minimum use of recycled content. The tried-and-tested German deposit system will therefore remain in place beyond the minimum requirements of the PPWR.
The existing requirements for implementing the Single-Use Plastics Directive will also remain in place. These include, in particular, the ban on the placing on the market of certain plastic carrier bags, as well as the obligation to offer reusable alternatives for single-use plastic food packaging and single-use beverage cups.
In addition, the VerpackDG clarifies procedural issues left open by the PPWR. For example, the EU declaration of conformity must in future be kept in either German or English, at the manufacturer’s discretion, and translated into German for the competent authority upon request. This provides some relief in terms of documentation, particularly for companies operating internationally.
Expanded responsibilities of the Central Packaging Register
The Central Packaging Register (ZSVR) remains the central enforcement body for German packaging law under the VerpackDG. Due to the expanded group of obligated parties introduced by the PPWR, it is assigned additional tasks, particularly in the areas of registration and extended producer responsibility. Another new feature is the introduction of automated authorisation procedures for manufacturers of packaging not subject to mandatory participation in the system, as well as for other organisations responsible for producer responsibility.
Ecological design of participation fees
Another new provision is Section 26a of the VerpackDG, which empowers the Federal Ministry for the Environment to issue specific guidelines on the eco-design of participation fees by means of a statutory order with the consent of the Bundesrat. Under Section 26 of the Packaging Act (VerpackDG), the schemes are obliged to create incentives for the use of recyclable materials and recycled content when calculating their participation fees. The forthcoming statutory order is intended to further specify these requirements.
A further practical extension is the direct obligation on schemes, other producer responsibility organisations, operators of sector-specific solutions and manufacturers who fulfil their extended producer responsibility on an individual basis to implement measures themselves to reduce and prevent packaging and packaging waste (Section 59 of the VerpackDG). The measures implemented must be documented annually by 31 March for the preceding calendar year and submitted to the competent state authority without delay upon request.
Not all provisions of the previous Packaging Act are being carried over unchanged. For instance, the previous exemptions for reusable packaging and for packaging made of lead crystal glass under the old Packaging Act cannot be incorporated into the VerpackDG due to the definitive application of the relevant PPWR requirements. At the same time, the Packaging Act (VerpackDG) contains, in Sections 14 to 18, its own temporary exemptions for plastic crates and pallets containing heavy metals, as well as for certain types of glass packaging, linked to requirements regarding return rates, declarations of conformity and annual reports. These new exemptions are intended as a transitional solution and will cease to apply as soon as the underlying EU decisions are repealed by delegated acts of the European Commission.
From 12 August 2026, a two-tier regulatory system will come into force: in future, the substantive requirements for packaging will primarily be derived from the PPWR, whilst the Packaging Act (VerpackDG) will govern the national registration, authorisation, monitoring and sanction mechanisms.
For businesses, this means that, from the PPWR’s entry into force on 12 August 2026, they must comply not only with the directly applicable EU Regulation but also, at the same time, with the national Packaging Act. Particular attention should be paid to the numerous transitional periods. Manufacturers already registered under the previous Packaging Act are automatically deemed to be registered, but must notify the authorities of any necessary changes by 12 November 2026, whilst manufacturers newly subject to registration must register by 12 September 2026.
As the offences subject to fines for PPWR breaches will only come into force from February 2027, companies should not only check their products and packaging for PPWR compliance, but also analyse which additional obligations will arise for them under the VerpackDG from August 2026. In particular, attention should also be paid to the core obligations under German packaging law that remain in force, namely the obligation to participate in a recycling scheme (Section 7 VerpackDG) and the declaration of completeness (Section 10 VerpackDG).
(Packaging Law Implementation Act of 13 July 2026, Federal Law Gazette 2026 I No. 207, published on 17 July 2026; Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024)
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