On 11 June 2026, the Bundestag passed the draft bill aligning German packing law with EU Regulation 2025/40. The CDU/CSU and SPD voted in favour, while the AfD, the Green Party Alliance and the Left opposed the bill. The existing Packaging Law Implementation Act will therefore be replaced and aligned with the EU requirements that come into force 18 August 2026. For producers and retailers, the new legislation marks a fundamental shift. Packaging laws will become more harmonised across Europe and will place greater emphasis on recyclability, material efficiency and the circular economy. The German Federal Government's objective is to reduce packaging waste while strengthening material cycles long-term.
Higher recycling targets and new material requirements
At the core of the reform are significantly higher recycling targets for plastic waste. The recycling rate is set to increase to 75% from 2028 and to 80% from 2030. As a result, companies will face greater pressure to ensure that packaging is designed for recyclability from the outset and that material circularity is considered throughout the design process. The legislation also introduces new requirements for the use of recycled content, as well as for the reusability and compostability of packaging. The aim is to gradually phase out plastics that are difficult to recycle, along with problematic substances such as certain per- and polyfluoroalkyl substances (PFAS). Oversized packaging will also be restricted, while clearer labelling requirements are intended to improve sorting and disposal.
During the parliamentary process, the parties CDU/CSU and SPD proposed a more environmentally orientated structure for participation fees. Recyclable and environmentally friendly packaging is, therefore, to be more economically attractive. This amendment was supported by the Green Party Alliance. The Bundestag has also been called upon to promptly adopt the statutory regulations required under Section 26a of the Packaging Law Implementation Act. These measures are intended to encourage greater recyclability and increased use of recycled materials. In addition, the government aims to strengthen the market for recycled materials produced in Germany and across the EU. Within the scope permitted under European law, only recycled materials produced within the EU are to count towards recycled content requirements.
Furthermore, the German federal government is expected to advocate at the EU level for additional requirements, faster approval procedures for recycled materials – particularly for food-contact and other sensitive applications – and a harmonised and, as far as possible, low-bureaucracy verification system. According to the CDU/CSU and SPD, the provisions on eco-modulation, recycled content and chemical recycling close a regulatory gap that previously existed between mechanical and chemical recycling. The legislation introduces an initial statutory recycled content quota of 5%, which is expected to increase from 2029 onwards, subject to the achievement of the relevant targets.
Eco-modulation as a market incentive
A key element of the reform is the introduction of eco-modulation: the ecological differentiation of packaging licence and disposal fees. The new regulations are designed to create stronger financial incentives for recyclable and resource-efficient packaging. For businesses, packaging design and material selection will increasingly have direct cost implications. Companies that invest in recyclable packaging are expected to benefit from lower fees, while those using packaging that is difficult to recycle will face higher charges.
Industry reactions
Initial reactions have been mixed. The Federal Association for Secondary Raw Materials and Waste Management (bvse Recycling Germany) has called for effective market incentives, stable markets for recycled materials and improved economic conditions through reduced bureaucracy and lower energy costs. The German Association of Local Public Utilities (VKU) welcomes the provisions relating to bio-waste management but urges caution regarding the treatment of compostable plastics. By contrast, Environmental Action Germany (DUH) criticises what they consider an excessive focus on recycling single-use packaging. They argue that reusable systems should receive much stronger support. Similarly, the World Wildlife Fund WWF Germany welcomes the introduction of eco-modulation but believes the legislation falls short in promoting waste prevention and reusable packaging systems.
The German Horticultural Association (ZVG) opposes additional obligations for transport packaging, arguing that they would increase administrative burdens and costs for businesses. The German Trade Association (HDE) likewise advocated throughout the legislative process for the European requirements to be implemented without additional national provisions. Following the removal of several proposed structural requirements during the legislative process, the retail sector considers the adopted Packaging Act to be a practical solution that imposes relatively little administrative burden.
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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