The European Commission has issued a Detailed Opinion under the TRIS procedure regarding the German VerpackDG. As a result, the standstill period for the German legislator has been extended until 17 August 2026. Germany officially responded on 27 May 2026 (more details), defending several national specificities — in particular existing registration, deposit-return and reporting obligations.
What does the extended standstill period mean?
Under the European TRIS procedure, Member States are required to notify technical regulations to the European Commission before they enter into force. During the so-called standstill period, the legislation may neither be finally adopted nor applied.
Where the Commission issues a Detailed Opinion — as is now the case for the VerpackDG — the standstill period is generally extended by an additional three months. The purpose is to address potential concerns regarding the compatibility of national rules with the European internal market or with already harmonised EU legislation.
Germany’s response of 27 May 2026 clearly demonstrates that Germany intends to maintain several national specificities, in particular:
existing registration and reporting obligations,
the national design of the deposit-return system,
certain terminology and legal definitions,
as well as national distinctions regarding recycling.
No impact on the direct applicability of the PPWR
The extended standstill period concerns only the German implementing legislation. The PPWR will nevertheless continue to apply directly in all Member States from 12 August 2026.
In particular, the following obligations remain unaffected:
manufacturer identification marking, and
conformity assessment of packaging, including technical documentation and the issuance of an EU Declaration of Conformity.
Where does legal uncertainty remain?
At present, the impact of the extended standstill period is primarily limited to the specific national implementation of extended producer responsibility (EPR) in Germany.
In particular, it remains unclear:
which national special rules will remain in place in the long term,
how future national registration and reporting obligations will interact with the harmonised PPWR framework, and
to what extent Germany may continue operating existing systems alongside the PPWR.
The regulatory uncertainty therefore mainly persists in relation to national EPR processes. Companies that are not yet properly registered should nevertheless complete their registrations without delay and notify the relevant established national registration authorities accordingly.
What companies should do now
Companies should continue their PPWR preparations consistently and without delay. This applies in particular to:
reviewing the future allocation of responsibilities within the supply chain,
implementing producer identification marking (directly applicable from 12 August 2026),
establishing conformity assessment and documentation processes (directly applicable from 12 August 2026),
preparing the EU Declaration of Conformity (directly applicable from 12 August 2026),
as well as assessing existing packaging portfolios against the new PPWR requirements.
At the same time, companies are advised to closely monitor further developments regarding the German VerpackDG as the first national implementing legislation under the PPWR, particularly with regard to future national EPR processes and registration requirements.
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