Consultation on the 2026 edition of the minimum standard

The methodology used to evaluate the recyclability of a packaging unit remains unchanged. To assess what share of a packaging unit can find a second life in typical applications for that material, actual sorting and recovery practices are taken into consideration. While in 2025 the minimum standard was adjusted to meet the new requirements of the EU Packaging and Packaging Waste Regulation (PPWR), this year's focus is on completing, simplifying and detailing the contents.

As in previous years, the minimum standard was developed together with experts from across the value chain. The extended group of experts that was gathered in the Expert Committee on Recycling-friendly Design in the previous year came together again, once more including experts from medium-sized companies, experts for specific material types, all system operators and the GS1 Forum Rezyklat.

Pursuant to section 21 VerpackG, the minimum standard is generally intended for system operators. When modulating participation fees, they are required to create incentives for packaging design for recyclability, taking into account actual sorting and recovery practices.

When the PPWR begins applying on 12 August 2026, including its time horizon for accepting only recyclable packaging on the market by 2030, the different determination standards will become much more relevant for producers. The final determination of recyclability will be in line with the provisions of the delegated act to be drafted by the EU Commission in accordance with Article 6 PPWR. However, section 26a VerpackDG (Packaging Law Implementation Act), which was recently adopted by the Bundestag, provides for the Federal Ministry for the Environment, Climate Action, Nature Conservation and Nuclear Safety (BMUKN) to issue delegated legislation setting out requirements for the ecological design of participation fees based on the minimum standard for determining the recyclability of packaging. This means that the minimum standard would be used to determine the recyclability of packaging for the time being.

Therefore, the ZSVR explicitly asks participants to point out during the consultation where the minimum standard might potentially contain methodological gaps that should be closed or require specification.

The 2026 edition of the minimum standard must be applied to packaging subject to system participation that is placed on the German market from 1 January 2027.

The minimum standard was first published on 1 September 2019. The draft now available for consultation updates both the content and structure of the 2025 edition. It will become the 2026 edition once it is published on 31 August 2026.

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As the minimum standard concerns incentivising the recyclability of packaging subject to system participation through the modulation of participation fees, stakeholders include the systems, producers and operators of sector-specific solutions.

Written submissions on the current consultation draft can be made by Friday, 17 July 2026. The English version of the consultation draft will be available soon. Please note that the English version is provided as a service. The German version is binding.

After the consultation, the minimum standard and the process for determining recyclability will be revised and undergo another round of discussion. The final version of the 2026 edition of the minimum standard will be available on the ZSVR website starting 31 August 2026.