The Packaging Law Implementation Act (VerpackDG) has passed the German federal government and has since been met with widespread approval in the recycling and plastics sectors. In particular, the introduction of regulatory authorisation for eco-modulation is regarded as an important step towards promoting recycling-friendly packaging design and the use of recycled materials in future through financial incentives. At the same time, several associations warn that key challenges relating to the implementation of the European Packaging Regulation (PPWR) remain unresolved.
BDE and bvse: Approval with specific demands
The German Association for Waste Management, Water and Circular Economy (abbr. BDE) is particularly critical of the lack of transitional provisions regarding the new European definition of a manufacturer. According to the association’s assessment, this could jeopardise the funding of the collection and sorting infrastructure for retail packaging in the second half of 2026. Furthermore, the BDE is calling for the retention of tried-and-tested collection systems for commercial and industrial packaging in order to clarify the division of responsibilities between dual systems and public waste management authorities.
Both the BDE and the Federal Association for Secondary Raw Materials and Waste Disposal (abbr. bvse – Recycling Germany) regard the enshrinement of eco-modulation in law as a crucial success of the parliamentary process. In the bvse’s view, the details should be finalised swiftly so that incentives for the use of recycled materials can take effect as early as 2027. The association cites the French model as a benchmark, under which, for example, producers with a higher proportion of recycled materials benefit from lower participation fees. At the same time, the bvse is calling for stable sales markets, increased demand through public procurement, faster approvals, competitive energy prices and better protection against competitive disadvantages caused by imports from countries with lower environmental standards.
Calls for more incentives for recycling and recycled materials
Plastics Europe Germany also welcomes the planned eco-modulation and the recognition of chemical recycling. From 2028, up to five per cent of the recycling target is to be met through chemical recycling processes. The association sees this as an important signal of openness to technology but considers the proposed target to be too low and calls for binding commitments to further expansion. Furthermore, better framework conditions regarding energy prices, bureaucracy and approval procedures are necessary to secure investment in Germany. The Alliance Packaging and Environment (abbr. AVU) also gives a positive assessment. The organisation expects that financial incentives for recycling-friendly packaging design and the use of recycled materials will promote investment in the circular economy. At the same time, the scheme must be designed to be as unbureaucratic as possible, and revenue from any surcharges must be used specifically to strengthen resource conservation. Furthermore, the AVU is calling for faster approval procedures for recycled materials in the food and cosmetics sectors, as well as stricter controls on imports.
The German Sustainable Business Association (abbr. BNV) also supports the implementation of eco-modulation and calls for the incentives for the use of recycled materials to take effect as planned as early as 2027. In the association’s view, the market for recycled plastics in particular should be strengthened and European producers given preference in order to make supply chains more robust and independent.
VERE e.V. remains in close contact with the relevant stakeholders and will continue to keep its members informed of further developments via the “VERE Insider”.
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