New Packaging Implementation Act (VerpackDG) - What changes in 2026
The Bundeskabinett has adopted the draft for a new Packaging Law Implementation Act (BMUKN: New Packaging Act improves waste prevention and recycling). Background to this initiative is that some provisions of the EU Packaging and Packaging Waste Regulation (PPWR) will take effect on 12 August 2026 and require legislative adaptions at national level. Now, the government proposal will proceed through the legislative process. The Bundestag still needs to pass the law. The Bundesrat will be involved.
What stays the same (for now)
The distinction between packaging required to participate in a scheme and packaging not required to participate in a scheme remains in place. (see News).
Currently not affected are labelling obligations. At present, the rules for packaging labels applicable in Europe resemble a regulatory patchwork. A harmonised labelling system will become mandatory no earlier than 12 August 2028. In the meantime, labelling rules that do already exist in some of the Member States continue to have effect.
From 12 August 2026, the PPWR definition of “producer” will apply in all EU Member states. Under the PPWR, the term ‘producer’ has a broad personal scope and therefore applies to a wide range of entities. Companies should check whether they qualify as a producer under the regulation.
The rules on registration will remain essentially the same. The newly introduced regime for extended producer responsibility (EPR) now requires producers to apply for authorisation on fulfilment of extended producer responsibility from the competent authority. This authorisation requirement does not apply if the producer has entrusted an authorized producer responsibility organisation carrying out the extended producer responsibility obligations on the producers behalf.
A significant change with practical implications is the introduction of a conformity assessment procedure for manufacturers.
How can we support you?
In our seminars on the EU Packaging and Packaging Waste Regulation (PPWR) we guide you through the regulatory changes using illustrative practical examples:
