Germany’s Federal Council Provides Further Recommendations for the Upcoming Packaging Law

This blog was originally posted on 16th April, 2026. Further regulatory developments may have occurred after publication. To keep up-to-date with the latest compliance news, sign up to our newsletter.

AUTHORED BY FREIDA WÜSCHNER GUBBINS, SENIOR GLOBAL REGULATORY COMPLIANCE SPECIALIST, COMPLIANCE & RISKS

Insight: The German Federal Council is urging for streamlined packaging laws and mandatory reusable mandates ahead of the EU’s August 2026 PPWR deadline. The recommendations focus on reducing bureaucracy through a centralized financial levy system and improving coordination between waste management authorities to protect ratepayers from rising costs.

Table of Contents

• EU-Mandated Measures for Reducing and Preventing Packaging Waste
• Mandatory Reusable Packaging
• The Relationship Between the Dual System and Public Waste Management Authorities]
• Next Steps for the German Packaging Recast
• Frequently Asked Questions

On March 27, the German Federal Council held a plenary session to discuss the draft law adapting national packaging legislation to Regulation (EU) 2025/40. During the session, state ministers voiced concerns and recommendations regarding the recast, highlighting the urgency of enacting updated legislation before the Packaging and Packaging Waste Regulation (PPWR) enters into force on August 12, 2026. This timeline is considered essential to providing businesses with a clear and stable legal framework for the German market.

During the session, the following issues were raised:

EU-Mandated Measures for Reducing and Preventing Packaging Waste

The Minister for North Rhine-Westphalia argued that the current requirement obliging approximately 60,000 stakeholders to implement and document independent waste-reduction measures creates excessive bureaucracy. He noted that individual efforts are less effective than pooling financial and organizational resources and are nearly impossible for authorities to monitor.

Consequently, it was suggested that stakeholders instead pay a revenue-based levy to a central organization, modeled after the system currently used in Austria. This organization would then coordinate and implement packaging waste reduction measures on a national scale.

Mandatory Reusable Packaging

Stagnating demand for reusable packaging was cited as a concern, as the current proposal lacks sufficient incentives to encourage the transition to environmentally friendly alternatives. To bridge this gap, it was suggested that the text be supplemented with mandatory provisions, specifically targeting the “to-go” and takeaway sectors.

The Relationship Between the Dual System and Public Waste Management Authorities

It was argued that the draft legislation does not resolve certain long standing inefficiencies in the existing system. In particular, stakeholders emphasized the need for a mandatory coordination agreement governing the shared use of collection structures for paper, cardboard, and carton (PPK). By formalizing the cooperation between public authorities and the dual systems, the Minister argued the proposal could better protect ratepayers from increased service costs.

Next Steps for the German Packaging Recast

While the Federal Council’s recommendations serve primarily as formal suggestions, they will be closely considered by the Bundestag and its relevant committees during the ongoing legislative process.

The recast is currently scheduled to enter into force on August 12, 2026, aligning with the application of the EU’s PPWR. However, the timeline remains tight; several legislative hurdles must be cleared before the Bundestag’s summer recess. Failure to finalize the act before this break could delay implementation, potentially leaving Germany with a brief regulatory gap where national legislation is not yet fully aligned with the new EU requirements.

Frequently Asked Questions

1. What is the primary deadline for the new packaging legislation? The legislation is scheduled to enter into force on August 12, 2026, to align with the application of the EU’s Packaging and Packaging Waste Regulation (PPWR).
2. What alternative was suggested to reduce bureaucracy for stakeholders? It was suggested that instead of 60,000 stakeholders documenting independent measures, they should pay a revenue-based levy to a central organization—similar to the Austrian system—which would implement waste reduction measures on a national scale.
3. Which specific sector was identified for mandatory reusable packaging provisions? The “to-go” and takeaway sectors were specifically targeted for mandatory provisions to address the stagnating demand for reusable packaging.
4. How could a mandatory coordination agreement benefit ratepayers? By formalizing the cooperation between public authorities and dual systems regarding collection structures (like PPK), it is argued that the proposal could better protect ratepayers from incurring additional service costs.What could happen if the legislative process is not finished before the summer recess? If the process is not completed before the Bundestag’s summer closure, implementation could be delayed, resulting in a brief regulatory gap where German law is not fully aligned with EU requirements.

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