European Commission Withdraws Detailed Opinion on Germany’s PPWR Implementation Act
The European Commission has withdrawn its previously issued Detailed Opinion concerning Germany’s TRIS notification 2026/0069/DE (more information).
As a result, the concerns originally raised by the Commission regarding the draft German Packaging Act amendment (VerpackDG) are now considered resolved.
Bitkom Compliance Solutions provided a analysis of the Commission’s objections and their implications last week (to the news).
As the Detailed Opinion has been withdrawn, the extended standstill period provided for under the TRIS procedure no longer applies. This means that the German legislator is no longer prevented from proceeding with the adoption of the legislation.
The Packaging Act amendment could therefore enter into force in time for the application of the Packaging and Packaging Waste Regulation (PPWR) on 12 August 2026, potentially making Germany the first Member State to adopt a dedicated national implementation framework for the new European packaging regime.
National implementation acts establish the administrative and enforcement structures necessary for the practical application of the PPWR at Member State level. While the PPWR is directly applicable across the European Union, national enforcement and implementation measures have not yet been adopted. As a result, companies continue to face significant legal and planning uncertainty, particularly with regard to registration requirements, competent authorities, and extended producer responsibility (EPR) processes.
What Companies Should Do Now
Regardless of developments at national level, companies should continue their preparations for the harmonised requirements introduced by the PPWR. Right now, particular attention should be paid to:
reviewing future roles and responsibilities throughout the supply chain;
implementing product and packaging marking requirements (applicable from 12 August 2026);
establishing conformity assessment and documentation processes (applicable from 12 August 2026);
preparing EU declarations of conformity (applicable from 12 August 2026); and
assessing existing packaging portfolios against the new PPWR requirements.
Given the ongoing development of national EPR frameworks and registration systems, companies should closely monitor legislative and regulatory developments across individual Member States.
Bitkom Compliance Solutions supports businesses in assessing PPWR obligations and tracking national implementation measures and enforcement structures across the EU. Feel free to request a proposal.
