VerpackDG instead of VerpackG: What will change for your company from 12 August 2026

Why is a new law needed at all?

The background is an EU regulation: the Packaging and Packaging Waste Regulation (PPWR). It entered into force across the EU on 11 February 2025 and will apply directly in every Member State, including Germany, from 12 August 2026. The key difference compared with an EU directive is that a regulation does not have to be transposed into national law; it applies automatically.

However, this creates an issue: the current German Packaging Act contains its own terminology and rules in many areas that could conflict with the EU regulation. To prevent German and EU law from running counter to each other, the legislator is repealing the VerpackG and replacing it with the VerpackDG. The new law supplements the EU regulation where it still leaves Member States room to establish their own rules and, for example, governs enforcement in Germany.

We advise you on all matters relating to the VerpackDG/PPWR:

Important to know: Two legal acts, one date

For your company, two legal sources will effectively apply at the same time from 12 August 2026:

• the EU Packaging Regulation (PPWR) itself, with directly applicable requirements relating to packaging design, recyclability, labelling and more;

• the German VerpackDG, which supplements the EU regulation where it allows national discretion, for example with regard to enforcement, the obligation to participate in a system and the packaging register.

Both texts must therefore be read together. Looking at the VerpackDG alone is not sufficient to understand all obligations.

How far has the legislative process progressed?

As of today (1 July 2026), the process has not yet been fully completed. This is not a minor detail; it is relevant to your planning:

• The Bundestag adopted the draft legislation, as amended by the Environment Committee, on 11 June 2026.

• The European Commission initially raised objections to the German draft as part of a notification procedure but withdrew them on 29 May 2026.

• The Bundesrat has placed the draft legislation on its agenda for 10 July 2026.

At the time this article was researched, it was not yet known whether the Bundesrat would approve the legislation or whether it would proceed to the Mediation Committee. We therefore recommend checking the status again shortly before 12 August 2026, for example via the Bundestag or Federal Ministry for the Environment websites, before relying on details that still depend on final adoption.

We advise you on all matters relating to the VerpackDG/PPWR:

Overview of the key substantive changes

Even though the final procedural step is still pending, the draft legislation and accompanying specialist publications already indicate several key changes.

1. New terminology: “producer” and “manufacturer”

The EU Packaging Regulation introduces its own standardised, EU-wide definitions, including for packaging “producers” and “manufacturers”. These terms will largely replace the previous definitions in the German Packaging Act. The VerpackDG introduces its own terminology only where this is necessary for national application.

This may initially sound technical, but it has practical consequences: Whether you qualify as a “producer” or “manufacturer” under the new definitions determines which obligations apply to you. As these terms require interpretation, companies should assess their classification at an early stage. The new definitions and the obligations linked to them will apply from 12 August 2026.

2. More packaging will be subject to the obligation to participate in a system

The obligation to license packaging through a dual system (Systembeteiligungspflicht) is expected to be extended. For example, so-called primary production packaging and, at least in part, transport packaging are expected to be covered where they typically become waste predominantly in private households or comparable places of waste generation.

What this specifically means for your own packaging depends on the individual case. The Central Agency Packaging Register (Zentrale Stelle Verpackungsregister, ZSVR), together with GVM Gesellschaft für Verpackungsmarktforschung, is currently developing a new catalogue of packaging subject to the obligation to participate in a system. Based on the information available to us, this catalogue is still under consultation and has not yet been finalised. Therefore, we cannot provide a definitive statement at this stage as to which specific types of packaging will ultimately be affected.

3. New authorisation requirement for certain manufacturers

Manufacturers of packaging that is not subject to the obligation to participate in a system will in future be required to apply for authorisation from the ZSVR before making this packaging available in Germany for the first time. Companies that already fulfil their extended producer responsibility through an authorised producer responsibility organisation will not require separate authorisation.

4. Transitional arrangements for existing system participation

For the transition to the new legal framework, the draft legislation provides that existing system participation agreements under the former Section 7 of the Packaging Act will generally remain valid, but no later than until 31 December 2026, unless different private-law agreements apply. Specialist discussions suggest that this provision may not be sufficient, partly because it may be unclear who still qualifies as a “manufacturer” under the new definitions and whether newly affected companies will be informed in time. This point has therefore not yet been conclusively resolved from either a political or practical perspective.

5. One combined declaration of completeness for 2026

There are expected to be no separate declarations under the old and new legal framework for the 2026 reporting year. Instead, companies will need to determine their quantities separately for the periods before and after 12 August 2026, but combine them in a single declaration of completeness for the entire year. This single declaration will also be subject to only one audit requirement.

The ZSVR’s detailed audit guidance for the declaration of completeness is expected to be updated for the new legislation, but was not yet available in final form when this article was published.

6. Increasing recycling rates

The recycling rate for plastic packaging waste is expected to rise to 75% from 2028 and to 80% from 2030. According to the draft legislation, the aim is to reduce the overall amount of packaging generated and strengthen the circular economy.

7. The LUCID Packaging Register will initially remain in place

The familiar LUCID Packaging Register will not be abolished. However, its content is expected to be adapted to align with the new EU-wide definitions. A fully harmonised EU-wide register is planned in the longer term, but according to the current status, the relevant EU implementing act is still missing. Once it is adopted, the German register must be adapted within 18 months. There is currently no specific date for this.