Consultation on the 'system participation requirement catalogue' applicable upon entry into force of the Packaging Law Implementation Act (VerpackDG catalogue)

The VerpackDG catalogue will replace the existing catalogue and serve as the new administrative regulation for all packaging made available in Germany for the first time as from 12 August 2026. It will form the basis for the Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR) to perform its duty of determining whether packaging is subject to system participation under the EU Packaging and Packaging Waste Regulation (PPWR) and the German Packaging Law Implementation Act (VerpackDG).

The consultation draft is based on the governmental draft

In the meantime, the Bundestag has adopted the government's draft legislation as amended by the Committee on the Environment. No amendments have been made regarding the assessment of the system participation requirement.

The VerpackDG catalogue consists of two parts, a General section and a Special section, both of which are part of this consultation.

The General section replaces the existing guideline. It introduces all relevant definitions and provides information about the structure and application of the VerpackDG catalogue. The Special section contains product sheets that provide information about ZSVR decisions regarding the system participation requirement of sales packaging and grouped packaging for different products.

The General section in the new catalogue also provides information about ZSVR decisions regarding the system participation requirement of transport packaging. Under the PPWR, transport packaging also includes packaging designed to ship goods (shipment packaging). Shipment packaging is always subject to system participation – without exception. Due to its reclassification as transport packaging, shipment packaging is no longer listed in the product sheets of the VerpackDG catalogue.

Amendments have been made especially in:

  • the 'coffee, tea, cocoa' product group – due to the new provision regarding the packaging status of pods, capsules and bags filled with coffee, tea or other beverages;

  • the 'office supplies' and 'DIY & gardening' product groups – due to the classification of solid art paints, wall plugs or screw nuts, screws, washers;

  • the 'tobacco products' product group – due to the delineation criterion for e-cigarette packaging; and

  • the 'dairy products' product group – in the product sheet for yoghurt, ready-made desserts (additional product sheet for yoghurt drinks, kefir).

New consultation on the first 2026 edition under the VerpackDG

Prior to publication of the VerpackDG catalogue in summer 2026, the ZSVR is holding a public consultation to give stakeholders the chance to submit their comments on the draft version. These comments will be discussed and evaluated with the competent authorities. 

The consultation draft published here contains 37 product groups and a total of 532 products.

Business reference

353602/01.SP.26#0001

Stakeholders

Above all producers, systems, operators of sector-specific solutions, other producer responsibility organisations, along with auditors of declarations of completeness and system auditors.

Participation

Written submissions on the current draft can be made by

Friday, 10 July 2026.

Submissions can be sent to the ZSVR by post or preferably by e-mail to katalog@verpackungsregister.org.

Once the consultation has been closed, the VerpackDG catalogue will undergo another round of discussion and revision. The final version will be published on the ZSVR's website, probably in August 2026.

Important

We ask for your understanding that we are unable to personally respond to your submissions given limited resources on our end and a large number of submissions. All submissions will be reviewed.