Home » Unpacking Germany’s Draft Packaging Act 2025: What is New, and What Stays the Same?

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Unpacking Germany’s Draft Packaging Act 2025: What is New, and What Stays the Same?

This blog was originally posted on 1st December, 2025. 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 REGULATORY COMPLIANCE SPECIALIST AND HANNAH JANKNECHT, REGULATORY COMPLIANCE SPECIALIST, COMPLIANCE & RISKS

On 17 November 2025, the German Federal Ministry for the Environment, Nature Conservation, Nuclear Safety and Consumer Protection (BMUV) proposed a Draft Act, the Verpackungsrecht-Durchführungsgesetz (VerpackDG), to facilitate the implementation of the EU’s new packaging and packaging waste Regulation 2025/40 (PPWR) in Germany.

Even though the PPWR is a regulation and will have direct applicability in Germany following its date of application on 12 August 2026, the new Draft has been necessitated by aspects of the PPWR, which allow member states to retain certain aspects of their packaging EPR systems, in addition to the ability to decide their own exemptions or waste management plans for certain packaging waste streams. Therefore, the proposed Packaging Act aims to establish which aspects of the previous German system will be retained, what new measures are required to supplement the PPWR’s implementation in Germany and to officially announce the repeal of the current German Packaging Act (VerpackG).

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Current German Obligations for Packaging Producers

The current German packaging Act (VerpackG), which is based on the EU’s Packaging and Packaging Waste Directive 94/62/EC (PPWD), contains many obligations for producers of packaging and packaging waste, which can be summarised as follows: packaging ‘producers’ defined as the first business entity to place packaging on the market, must register with the ‘LUCID packaging register’, then they must enter into a ‘system participation agreement’ with a Dual System (or ‘system operator’), if the type of packaging they produce obliges it. To complete this process, the producer will require the details they received during the completion of their registration and the producer will subsequently be required to report their packaging volumes to both their system operator and the LUCID Packaging Register. Failure to comply with the Act is classified as an administrative offence, which can lead to marketing prohibitions and significant fines of up to 200,000 euros.

What Will Remain?

Under the Draft proposal, the Ministry is proposing the retention of many aspects of the current EPR system which are unique to Germany, such as:

1. The Zentrale Stelle Verpackungsregister (ZSVR) or Central Agency Packaging Register will continue to act as the state approved authority for ensuring the implementation of the packaging Act. The Draft has also clarified that the ZSVR will retain its existing tasks i.e. surveilling compliance, operating the LUCID Packaging Register, reviewing packaging volume reports and declarations of completeness, as well as reviewing volume flow records and recycling rates.
2. The requirement to conclude a ‘system participation’ agreement, will continue to apply to packaging which is subject to system participation, i.e. packaging which typically accumulates as waste with private final consumers. Under this obligation, packaging producers of in scope packaging must register and pay a fee for that packaging’s recycling. Packaging producers can conclude a system participation agreement with the system operator of their choice. An overview of system operators in German can be found on this link. Currently, the cost for participating in a system is dependent on a number of different factors such as the volume and material type of packaging.
3. The ‘dual system’ concept, which is used to describe companies or ‘system operators’ who packaging producers engage in system participation agreements with for the collection, sorting, reuse or recycling of their waste packaging.
4. The obligation to submit a ‘declaration of completeness‘ detailing packaging volumes from the previous calendar year will be retained, and the current annual submission deadline of May 15th will be maintained. This obligation will continue to apply to businesses whose packaging volumes in the previous calendar year reached or exceeded at least one of the following three volume thresholds:
- Glass: 80,000 kg
- Paper, paperboard, cardboard in total: 50,000 kg
- Ferrous metals + aluminium + plastics + beverage cartons + other composites in total: 30,000 kg
- Declarations of completeness are to continue to be submitted electronically to the LUCID Packaging Register and should include details on the material types and masses of all the retail and outer packaging placed on the German market in the previous calendar year, including those that accumulated as waste in industrial or large commercial enterprise settings after use.
5. Finally, despite the PPWR mandating the repeal of Commission Decision 97/129/EC (establishing an identification system for packaging materials), the Draft retains this system in Annex 4 for packaging labelling. Nevertheless, the EU has yet to announce details for its harmonised label for packaging material labelling, which will become mandatory in all EU member states from either 12 August 2028, or 24 months after the implementing acts enter into force, whichever is later.

What is Going to Change in 2026 and Beyond?

Although the German legislator aims to preserve as many aspects of the current packaging system as possible, the new EU regulation makes certain changes to the existing framework necessary.

Manufacturers and distributors will have to examine the following questions to ensure their business stays compliant.

What Types of Packaging are Subject to System Participation?

One of the main peculiarities of the current German Packaging Act is the distinction between system-participating packaging and packaging that is not subject to system participation. The Draft Act retains this distinction, but it introduces some changes to the definition of system‑participating packaging.

The new definition includes:

Sales and outer packaging,
Primary production packaging,
Transport packaging, which after use is typically disposed of as waste by consumers or comparable collection points
Service packaging

Under this definition, packaging is no longer required to be filled with goods, since this aspect is now addressed in the manufacturer definition of the EU Packaging Regulation. The draft furthermore explicitly includes primary production packaging, a new term introduced by the EU regulation. Transport packaging that typically ends up as waste with private end consumers, including e-commerce packaging and packaging used for in-person sales with transport packaging, is also subject to system participation.

Packaging types that are not subject to system-participation are:

Reusable packaging whose actual return and reuse is facilitated by an existing reuse system,
Single-use beverage packaging that is subject to a deposit requirement pursuant to Section 36,
Sales packaging for goods containing harmful substances,
Packaging that is demonstrably not supplied to end consumers in Germany.

How Will the Obligations for Packaging Manufacturers Change?

1. Manufacturers of system-participating packaging

As mentioned above, the obligations for manufacturers of system-participating packaging remain largely the same. They are required to join one or more systems ensuring nationwide collection and recycling before placing packaging on the market. Instead of joining a general packaging system, manufacturers of system-participating packaging can choose to join an authorized industry-based solution (Branchenlösungen) for packaging waste generated at comparable commercial or industrial points such as hotels or hospitals.

2. Manufacturers of packaging not subject to system-participation

Under the current Packaging Act from 2017, manufacturers of other types of packaging are required to register with the ZSVR from July 2022, but they are not required to participate in an extended producer responsibility system.

This is going to change under the new law, which will make non-system participating packaging subject to EPR requirements. For non-system participating packaging, manufacturers can choose one of the following options:

Join an extended producer responsibility organization/ packaging system for non-system participating packaging
Set up their own take-back system

What are the Authorization Requirements Applicable to Packaging Systems and Individual Manufacturers?

Under the current German Packaging Act, only packaging systems are required to obtain authorization from the ZSVR. The new Draft Act, however, extends this requirement to other Extended Producer Responsibility organizations that handle packaging not subject to system participation, as well as to manufacturers that opt to establish their own take-back systems.

Packaging Systems (Article 15 and 16): Systems must apply for authorization from the ZSVR before operating, ensuring they meet requirements such as comprehensive collection structures, sorting and recycling capacities, financial self-control measures, and insolvency-proof guarantees. The approval process includes a public announcement and an 18-week application review period.

Other EPR Organizations (Section 17): Unlike systems covered under Section 15, these organizations handle packaging waste mostly from commercial and industrial sectors and have less stringent requirements related to collection infrastructure or coordination with public waste management. The authorization process is designed to be less bureaucratic and largely automated, focusing on confirming geographic coverage, collection systems, necessary agreements for waste management, financial security, and compliance with extended producer responsibility obligations.

Individual Manufacturers (Section 14): Manufacturers of packaging not subject to system-participation must now obtain authorization from the ZSVR before placing such packaging on the German market, unless they transfer their extended producer responsibility to an approved organization under Section 17. The approval process includes meeting requirements such as free take-back and recycling obligations, labeling, financial security to cover costs in case of insolvency, and ensuring proper pre-treatment and high-quality recycling of packaging materials.

What are the New Requirements for Packaging Minimization and How Will They Be Funded?

According to Article 51(3) of the EU Packaging Regulation, member states must ensure that Extended Producer Responsibility (EPR) regimes and deposit-return systems allocate a minimum portion of their budgets to the funding of reduction and prevention measures.

Section 24 of the German Draft Act provides for the establishment and financing of an organization responsible for these activities (Organisation für Reduzierungs- und Präventionsmaßnahmen), to be founded by 1 January 2027, and funded by producers, systems, and other responsible entities . To this end, packaging systems, other PROs and producers that chose to organize their obligations individually will be required to pay 5 euro per tonne of packaging to the new organization.

What Will the New Recycling Quotas Look Like?

The new recycling quotas for packaging systems are set out in Section 33 of the Draft Act.

Contrary to EU law, the quotas specified in the German Act are based on the supply to recycling and not on the output from recycling, and they are calculated accordingly.

Packaging systems are required to ensure that annually at least the following percentages by weight are sent to recycling:

90% for glass
90% for paper, cardboard, and cartons (excluding liquid cartons)
80% for liquid cartons
90% for ferrous metals (increasing to 95% from 1 January 2028)
90% for aluminum (increasing to 95% from 1 January 2028) and
75% for plastics by 1 January 2028 (rising to 80% by 1 January 2030). At least 63% of involved plastic packaging is required to undergo material recycling specifically, increasing to 70% in 2028 and 75% in 2030.

For plastic waste, the quotas will change in two ways: From 2028 onwards, instead of a recovery quota, a recycling quota of 75 percent applies. Of this, 70 percent must be achieved through material recycling. The remaining 5% can be fulfilled by other recycling methods, which can include chemical recycling.

What’s Next?

The Ministry is currently conducting a public consultation with associations and federal states (Länder- und Verbändeanhörung), closing on 5 December 2025. The Federal Cabinet intends to pass the Draft in the first quarter of 2026, after which it will be discussed by the Parliament and Council.

It is important to note that some measures at the EU level will have to be implemented through future implementing acts, and it is not yet clear what their full content will be. This implies potential additional changes to the German Packaging Act in the coming years to align with those future EU acts.

Want to find out more about Global Packaging Regulations? Check out our webinar-on-demand.

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