PPWR: German Implementation Act Adopted

Following its publication in the Federal Law Gazette on 17 July 2026, the new German Packaging Law Implementation Act (VerpackDG) replaces the previous Packaging Act (VerpackG). 

The VerpackDG supplements the requirements of the EU Packaging and Packaging Waste Regulation, which will apply directly in all Member States from 12 August 2026, by establishing national responsibilities, procedures and implementing provisions. The EU Regulation introduces more harmonised requirements across the EU concerning the prevention, design, labelling, reuse and recycling of packaging. 

Key Changes 

The requirements of the new German Packaging Act (VerpackDG) particularly affect companies that place packaging on the market in Germany, as well as systems and organisations that assume extended producer responsibility obligations. 

The basic structures of the German Packaging Act (VerpackG) that was replaced will remain in place. However, there are a number of significant changes that companies need to take into account. 

The key changes include: 

  • a broader range of companies will fall within the definition of “producer” and will therefore be subject to producer obligations. This will include, for example, companies that manufacture empty transport, service or primary packaging pursuant to Article 3(15)(a) and (c) PPWR.

  • new authorisation requirements for producer responsibility organisations; 

  • mandatory measures to prevent packaging waste and promote reusable and refill systems; and 

  • higher recycling targets for plastics, aluminium and ferrous metals from 2028. 

What companies should do now 

Irrespective of this, companies should continue to prepare consistently for the harmonised requirements of the PPWR that will apply throughout the EU. This applies in particular to: 

  • reviewing the future allocation of roles within the supply chain;  

  • implementing producer identification requirements, which will apply directly from 12 August 2026;  

  • establishing compliance and documentation processes, which will apply directly from 12 August 2026;  

  • preparing the EU declaration of conformity, which will apply directly from 12 August 2026; and  

  • assessing existing packaging portfolios against the new PPWR requirements.  

Companies should also closely monitor developments in the individual Member States regarding future national EPR processes and registration requirements. 

Bitkom Compliance Solutions is pleased to support you in analysing the PPWR requirements and monitoring national implementing legislation and enforcement structures. Please submit your request for a quotation here.