PPWR and German Packaging Law Implementation Act (VerpackDG) – what is changing for you
On 12 August 2026, the EU Packaging and Packaging Waste Regulation (PPWR), together with the German Packaging Law Implementation Act (VerpackDG), will replace the existing German Verpackungsgesetz (Packaging Act).
The basic obligations for packaging subject to system participation – registration, system participation and data reporting – will remain in place. What will change, however, are the rules governing who is required to fulfil these obligations and under what conditions. These will be different from those previously in force. There will also be new responsibilities. On this page, we have provided an overview of the most important changes.
Manufacturers and producers: who bears what responsibility?
The PPWR makes a distinction between …
... manufacturers, who are responsible for packaging conformity. By providing the technical documentation and the declaration of conformity, they demonstrate that the packaging meets the PPWR’s requirements.
... producers, who bear extended producer responsibility (EPR) in the EU Member State where the packaging becomes waste. They are mainly responsible for financing packaging recycling and for fulfilling the associated registration and reporting obligations.
Principles for determining who is the manufacturer and who is the producer
Brand precedence: if a company has packaging or packaged products designed or manufactured under its own name or brand, it is itself regarded as the manufacturer. Under the brand principle, the company is also the producer of the packaging or packaged products.
If packaging or a packaged product bears neither the name nor the brand of the ordering company, the producer and the manufacturer are identified separately in two stages:
1. Manufacturer: the key factor is the type of packaging and the point in time when it becomes 'complete':
Transport, service or primary production packaging: for these types of packaging, obligations may arise even when they are empty.
Retail and grouped packaging: for these types of packaging, obligations generally only arise once they have been filled.
Please note that for every unit of packaging, there is exactly one manufacturer across the entire EU.
2. Producer: who is deemed the producer depends on the EU Member State where a packaging unit becomes waste (domestic precedence). The key factor is who is the first company in the domestic supply chain.
A foreign company is only considered the producer if it ships from abroad directly to a (private or commercial) end user.
Please note that if the manufacturer is based in the same EU Member State where the packaging becomes waste, it is also considered the producer because there is no other company further upstream in the supply chain.
Further new obligations under the PPWR and the VerpackDG
Companies based abroad that, without having a branch in Germany, sell empty packaging or packaged products directly to end consumers in Germany have, until now, been able to appoint an authorised representative on a voluntary basis. From 12 August 2026, they will be obliged to do so. The authorised representative assumes responsibility on behalf of the company under obligation for fulfilling all extended producer responsibility obligations in Germany. There is one exception: registration with the LUCID Packaging Register remains the manufacturer’s personal responsibility. No exemption can be made.
Please note that the authorised representative must be specified in the LUCID Packaging Register at the time of initial registration. Producers based abroad who are already registered will, from 12 August 2026, be automatically notified of a missing authorisation once they have logged in, and will be required to provide this information.
For packaging not subject to system participation, the existing obligations under extended producer responsibility – in particular regarding the return of packaging or the transfer of packaging for re-use or recovery – continue to apply. What is new is that additional authorisation from the ZSVR will be required for this from the end of 2027. Producers may fulfil these obligations themselves or delegate them (in whole or in part) to one or more other producer responsibility organisations (oPROs) – in all cases, authorisation from the ZSVR is required for the producer and/or the oPRO.
Please note: the VerpackDG contains the transitional provision that producers may operate without authorisation until 31 December 2027, and oPROs until 31 October 2027. The ZSVR will develop and provide electronic authorisation procedures for this. Authorisation requires paying a fee.
The PPWR’s objectives at a glance
The PPWR establishes, for the first time, a uniform European framework covering the entire life cycle of packaging and replaces individual national regulations with common rules and targets for all EU Member States. The aim is to ensure that packaging can be re-used, recycled and remain in the circular economy as a raw material.
Prevent packaging waste:
packaging should be reduced to a minimum. This includes empty spaces, especially in the case of shipment packaging.
Promote re-use and recycling:
packaging should be re-used more widely and designed in such a way as to allow for high-quality recycling.
Close material cycles:
the complexity of packaging materials should be reduced and the use of recycled materials, particularly in plastic packaging, should be increased.
Establish uniform rules within the EU single market:
binding EU-wide requirements are intended to remove barriers to trade and promote a level playing field.
Promote innovation and consumer information:
the PPWR promotes new, recyclable packaging solutions and better information about proper disposal.
