Changes to the Packaging Act 2024/2025

The Packaging Act has been in force since 2019 and implements the European Packaging Directive 94/62/EC. It regulates the responsibility of manufacturers, retailers and online marketplaces for packaging. The aim is to reduce waste, promote the circular economy and protect the environment. The latest amendment (VerpackG3, in force since May 16, 2023) and the EU Packaging Regulation (PPWR, Regulation (EU) 2025/40, in force since February 11, 2025) introduce new standards that will apply throughout the EU from the end of 2025. In Germany, the Packaging Act remains relevant for national regulations, such as registration with the LUCID Packaging Register of the Central Agency Packaging Register (ZSVR).

The most important changes for 2024/2025

Extended mandatory deposit for dairy products

Since January 1, 2024, the mandatory deposit has been extended to single-use plastic beverage bottles and cans. Milk, mixed milk drinks (at least 50% milk content) or drinkable milk products such as yogurt, kefir or buttermilk are now subject to a deposit. This regulation supplements the mandatory deposit for drinks such as water, beer or soft drinks that has been in force since 2022 and aims to increase the separate collection rate and reduce packaging waste in the environment (littering). In accordance with Section 31 (4) sentence 2 VerpackG, the mandatory deposit will also apply to milk and milk products in disposable plastic drinks bottles with a filling volume of 0.1 to 3 liters from 1 January 2024.

This packaging must be registered in the LUCID packaging register. The obligation to report quantities to LUCID does not apply to packaging subject to a deposit, as this is recorded via the deposit system. The packaging in question must bear a deposit symbol and be integrated into a take-back system, e.g. via reverse vending machines in supermarkets. The deposit is at least 0.25 euros per unit. For companies that sell dairy products in disposable packaging, this means adapting packaging processes and possibly investing in new labeling or take-back systems.

Obligation to use permanently attached closures

Since July 3, 2024, single-use plastic beverage bottles with a filling volume of up to 3 liters may only be placed on the market with permanently attached closures. Loose closures, which often end up in the environment, are thus to be avoided. This regulation applies to all types of beverages, including water, soft drinks, juices and dairy products, and requires that closures remain attached to the bottle even after opening, for example by means of flexible plastic strips or hinges. According to Section 3 (1) of the Single-Use Plastic Labeling Ordinance (EWKKennzV) in conjunction with Section 30 VerpackG, such closures must remain attached to the container for the entire period of use.

Distributors had to adapt their packaging designs, which entails higher production costs due to new closure systems or retrofitted machines. It must be ensured that the new closures do not impair the recyclability of the bottle, as this affects the license fees with dual systems. The changeover requires close cooperation with packaging suppliers in order to meet the requirements of EU Directive 2019/904 (Single-Use Plastics Directive).

Minimum recyclate content for single-use plastic drinks bottles

Since January 1, 2025, single-use PET plastic drinks bottles must contain at least 25% recycled plastic (recyclate). This proportion will increase to 30% for all single-use plastic drinks bottles from 2030. This regulation applies to beverages such as water, soft drinks and dairy products and obliges manufacturers and distributors to provide evidence of the recycled content. According to Section 30a (1) VerpackG, PET-based single-use plastic drinks bottles may only be placed on the market from January 1, 2025 if they consist of at least 25% recycled plastic, including caps and lids.

The requirement promotes the circular economy, but can pose challenges for companies. Recyclates are often more expensive and harder to obtain. Therefore, supply chains need to be adapted to source certified recyclates and check the recyclability of packaging to benefit from lower license fees. Verification requires precise documentation, for example through supplier certificates or audits.

Further changes in overview:

Stricter recycling quotas

The Packaging Act sets ambitious recycling targets. By the end of 2025, 65% of all packaging waste is to be recycled, by 2030 even 70%. The following quotas apply to individual materials:

•  Plastics: 50% (2025), 55% (2030)
• Glass: 70% (2025), 75% (2030)
• Paper/cardboard: 75% (2025), 85% (2030)
  Companies should review their processes in order to meet these quotas.

Ban on certain single-use plastics

In addition to the permanently attached closures, products such as single-use drinking straws, plastic cutlery and to-go cups made from expanded polystyrene have been banned since 2021. The PPWR extends these bans from 2030, for example to single-use packaging for fresh fruit and vegetables or small cosmetics packaging in hotels.

Promotion of reusable packaging

Reusable packaging is a core element of the new regulations. Since 2023, catering businesses have had to offer reusable options for to-go products. The planned amendment (VerpackG4) introduces a mandatory reusable quota, e.g. 10% reusable packaging in the take-away sector by 2030 (in accordance with PPWR). License fees for packaging subject to system participation will be more closely aligned with ecological criteria (Section 21 VerpackG).