The Packaging Law Implementation Act (VerpackDG) forms Germany’s implementation of European packaging policy and is intended to transpose the provisions of the EU Packaging and Packaging Waste Regulation (PPWR) into national law. The goal is to align the handling of packaging in Germany more closely with the circular economy, reduce waste and improve recycling. For producers, retailers and, in particular, small and medium-sized enterprises (SMEs), the law primarily sets new framework conditions in the areas of product responsibility, recycling requirements and the financing of waste management structures.
Although some additional structures and reporting obligations have been removed from the original draft bill, key issues remain contentious. Special attention is given to national regulations that exceed EU standards and new duties aimed at encouraging reusable packaging and recycling, as well as innovative funding strategies for preventing waste. Whilst many organisations and associations are calling for even more far-reaching measures, producers and SMEs point to the risks of rising costs and increased bureaucracy. The positions of the various stakeholders therefore vary accordingly.
VERE has also already taken a clear stance on this and is advocating for practical solutions in the interests of businesses. For instance, labelling requirements should only apply once the European PPWR comes into force, to avoid duplicate adjustments and unnecessary costs. Furthermore, VERE recommends streamlining the reporting processes: the current distinction between third-party agents and authorised representatives for data reporting should be abolished so that foreign dealers and producers can register entirely via authorised representatives. This would significantly simplify many processes and ensure registers are always kept up to date.
Furthermore, the association calls for the earlier effective date of notices terminating authorisations, practical guidelines on security deposits, and the centralisation of authorisation procedures at the Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR). At the same time, VERE opposes national deviations from the European PPWR to avoid placing additional burdens on producers. Further proposals from the association aim to avoid unrealistic obligations – such as separate collection in public spaces – prevent disproportionate cost increases, limit new barriers to market entry, and continue with tried-and-tested systems.
The industry association Plastics Europe Germany warns against misguided industrial policy. The optimal approach would be to implement the EU Packaging Directive directly, thereby eliminating the need for separate national regulations. This would reduce unnecessary burdens on companies and facilitate investment without additional obstacles. For retailers and producers in particular, this would mean additional costs, bureaucracy and planning uncertainty.
Other stakeholders, however, are pursuing a significantly more regulated approach. The leading municipal associations, represented by the German Association of Local Public Utilities (VKU) and the German Association of District Authorities (DLT), welcome the national implementation in principle but criticise the lack of authority to set fees vis-à-vis the dual systems. They are calling for additional enforcement tools for municipal fee claims and a stronger role for municipal waste management in implementing the new regulations. From the perspective of many companies, however, such additional powers would primarily entail new financial obligations and increased administrative requirements.
The German Federal Association for Sustainable Economy (BNW) sees the new Packaging Law Implementation Act as a missed opportunity for the circular economy and would like to go a step further here, for example, with ecologically modulated licence fees. These are intended to price packaging differently according to criteria such as recyclability or the use of recycled materials, thereby creating additional incentives for recycling. For retailers and producers, however, such a model would mean additional costs and less transparent fee structures. The association believes that the draft bill failed to clearly outline the necessary criteria, which could result in the reform simply delaying action rather than achieving meaningful change. Furthermore, the BNW is calling for more effective investment incentives for high-quality plastic recycling systems – which, in practice, could also entail new regulatory requirements and costs for businesses.
Environmental organisations are also calling for more substantial and effective measures. WWF Germany is calling for clear steps towards waste reduction, greater promotion of reusable solutions and a fundamental shift of the packaging system towards a comprehensive circular economy. A sustainable structure must be built up consistently. However, such a far-reaching system overhaul would result in additional adjustments, investments and stricter regulatory requirements for businesses.
The German Nature And Biodiversity Conservation Union (NABU) also advocates additional structural measures, such as a mandatory organisation for waste prevention and reusable packaging or greater funding for prevention measures through dual systems and deposit and return schemes. Criticism is also directed at the removal of a recycling target for paper-based composite packaging and the lack of additional investment incentives. The association views targets as remaining ineffective without additional financial instruments. Accordingly, NABU calls for additional commitments to advance the use of reusable packaging, encourage waste prevention, and support high-quality recycling initiatives. For producers, however, such demands would mean new obligations, additional financing systems and thus further costs.
Another critical voice comes from Environmental Action Germany (DUH). In their view, removing any planned financing mechanism for reusable systems – originally a mandatory contribution of five euros per tonne of single-use packaging – significantly weakens the law. The proposed non-binding minimum budgets are insufficient to promote reusable packaging. The organisation is therefore calling for an obligatory financing mechanism or a nationwide levy on single-use packaging, citing local examples such as Tübingen and Konstanz. Such an instance would, of course, result in additional costs for producers, especially regarding single-use packaging.
The Packaging Law Implementation Act generally highlights the tensions between economic interests, local authority responsibilities and environmental policy within Germany. While many organisations are advocating for more obligations, levies, and regulatory measures, industry and producers highlight the potential for competitive disadvantages, increased costs, and greater regulatory uncertainties.
For producers, retailers and SMEs in general, several questions still remain unanswered. VERE is therefore actively committed to promoting practical and economically viable solutions and avoiding unnecessary extra strains on businesses. The association is committed to advocating for its members' interests within the political sphere whilst constructively contributing to the practical further development of packaging legislation.
Furthermore, VERE e.V. stays in contact with all relevant stakeholders and keeps its members informed of further developments via the “VERE Insider”.
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If you require individual training on the EU Packaging Regulation or an assessment of your role within your supply chain, VERE e.V. recommends the PPWR training course from trade-e-bility.
Please feel free to contact our colleagues at trade-e-bility directly on +49 40/750687-300 or send us an email.
