PPWR vs. VerpackG: What Changes in Germany
Germany is replacing VerpackG with VerpackDG to implement the PPWR. Compare old and new rules, deadlines, and recycling targets for companies selling into Germany.
Germany's Packaging Law Gets a Complete Overhaul
Germany's Packaging Act (Verpackungsgesetz, or VerpackG) has governed packaging obligations for producers and distributors since 2019. That era is ending. On 11 February 2026, the German cabinet adopted the draft of the Verpackungsrecht-Durchführungsgesetz (VerpackDG) -- the new act that will completely replace VerpackG. It is expected to enter into force on 12 August 2026, the same date the EU Packaging and Packaging Waste Regulation (EU) 2025/40 -- the PPWR -- becomes directly applicable.
If you sell products into Germany from elsewhere in Europe, the UK, or beyond, this matters. The PPWR sets the substantive requirements -- recyclability, recycled content, labelling -- but Germany's VerpackDG handles the national enforcement machinery: registration, financing, penalties, and institutional responsibilities. Understanding both layers is essential.
Note: the VerpackDG is sometimes informally called "VerpackG 2" in industry circles. That is not the official name. The correct title is Verpackungsrecht-Durchführungsgesetz.
What Stays the Same
Several core elements of the current VerpackG system carry over into the VerpackDG:
- LUCID register -- The central packaging register at the ZSVR (Zentrale Stelle Verpackungsregister) remains the registration instrument. Every producer placing packaging on the German market must register.
- Dual system structure -- Producer responsibility organisations like Der Grüne Punkt (DSD), Interseroh, Reclay, and others continue operating. Producers must still participate in a dual system to finance household packaging collection.
- Deposit system (Pfand) -- The single-use deposit system for beverage containers stays in place.
- Declarations of completeness -- Companies exceeding volume thresholds must still file annual declarations proving full system participation.
- ZSVR oversight -- The ZSVR retains its supervisory and enforcement functions, and will gain expanded powers under the VerpackDG.
Five Key Changes
1. Broader Producer Definition
The VerpackG defined "first distributor" (Erstinverkehrbringer) relatively narrowly. Under the PPWR and VerpackDG, the producer definition expands significantly. More companies will qualify as "producers" under packaging law -- particularly fulfilment service providers and companies that have products packaged under their own brand. Article 3 of Regulation (EU) 2025/40 defines "producer" more broadly than the old VerpackG.
2. B2B Packaging Obligations
Until now, transport packaging, B2B sales packaging, and industrial packaging had lighter obligations. That changes fundamentally:
- From 1 January 2028, B2B packaging must be registered with the ZSVR
- Alternatively, extended producer responsibility (EPR) can be contractually transferred to the buyer
- Producers of transport, reusable, and industrial packaging must now contribute to end-of-life financing
Companies operating exclusively in B2B that previously had minimal packaging obligations face substantial new requirements.
3. Formal Authorisation for All PROs
The VerpackDG requires formal authorisation for all producer responsibility organisations, including individual producers who wish to organise their own take-back. This replaces the previous structure where dual systems were the primary authorised actors.
4. Expanded Financing
Previously, dual systems bore the costs of collection and recovery, funded by licence fees from consumer packaging producers. The VerpackDG widens the circle of financing obligations to include producers of transport packaging, reusable packaging, and industrial packaging.
5. Higher Fines
The penalty framework increases to up to EUR 200,000 for infringements. This is a significant increase from the VerpackG regime and signals that German authorities intend to enforce the new rules firmly.
New Recycling Targets (Effective 1 January 2028)
| Material | Recycling Rate from 2028 | From 2030 |
|---|---|---|
| Aluminium / ferrous metals | 95% | -- |
| Glass | 90% | -- |
| Paper / cardboard | 90% | -- |
| Plastics overall | 75% | 80% |
| Plastics mechanical (minimum) | 70% | 75% |
Notably, chemical recycling now counts towards plastic recycling quotas -- a change from the previous VerpackG framework, which only recognised mechanical recycling.
The 6-Month Grace Period
A six-month grace period applies for PPWR compliance offences from 12 August 2026 to 12 February 2027. During this window, enforcement authorities are expected to take a lighter approach to penalties, provided companies demonstrate genuine efforts toward compliance.
This is not an extension of the deadline -- the rules apply from 12 August 2026. It is simply a period of milder enforcement. Do not rely on it as a cushion: market surveillance authorities and competitors will be watching closely.
Key Dates
| Date | Event |
|---|---|
| 11 February 2026 | German cabinet adopts VerpackDG draft |
| 12 August 2026 | PPWR directly applicable; VerpackDG enters into force |
| 12 Aug 2026 -- 12 Feb 2027 | 6-month grace period for PPWR offences |
| 1 January 2028 | New recycling targets apply; B2B registration with ZSVR required |
| 2030 | Stricter plastics recycling quotas (80% / 75% mechanical minimum) |
What You Should Do Now
Check your producer status under the expanded PPWR definition in Article 3 of Regulation (EU) 2025/40. If you sell into Germany, you may now qualify as a producer even if you did not under VerpackG.
Update your LUCID registration to ensure all packaging types are covered -- including B2B packaging.
Audit your supply chain for recyclability (Article 6 PPWR), substance restrictions including PFAS (Article 5), and recycled content declarations (Article 7).
Start documenting B2B packaging now. The ZSVR registration requirement starts 1 January 2028, but data collection should begin well in advance.
Prepare your Declaration of Conformity under Article 12 of the PPWR for each packaging type you place on the market.
Conclusion
The VerpackG served Germany well for seven years. Its successor, the VerpackDG, is not a minor revision -- it is a fundamental restructuring driven by the European PPWR. The substantive requirements come from Brussels; the enforcement comes from Berlin.
Companies that act early will avoid fines of up to EUR 200,000 and gain a competitive advantage. Those who wait until the last minute will find the regulatory landscape has shifted beneath them.
Sources:
- Gleiss Lutz: New German Act Set to Implement EU Packaging Regulation
- Packaging Journal: Packaging -- This Will Change with the New Packaging Law
- Cattwyk: Implementation of the EU Packaging and Packaging Waste Regulation (PPWR) in Germany
Ready to start your PPWR compliance journey? Create your free account and generate your first Declaration of Conformity in minutes.