New packaging legislation in Germany

02.09.2026

12 August 2026 marked not only the entry into force of the PPWR. At the same time, the Packaging Law Implementation Act (VerpackDG) completely replaced the Packaging Act (VerpackG). On 31 August 2026, the new minimum standard of the ZSVR was also published. Together, these changes alter the basis on which licence fees for packaging waste in Germany will be calculated in future.

The key points in four bullet points:

The 2026 Minimum Standard introduces few material-related changes for packaging materials such as ppg > sie. Like the 2025 version, it places greater emphasis on harmonisation with the PPWR.
The minimum standard is evolving from a market reference to a binding basis for calculation. In future, this will also apply to distributors, and no longer just to the dual systems.
The eco-modulation of licence fees, which has been planned since 2019, is thus becoming more concrete. Section 26a of the Packaging Act (VerpackDG) obliges the Federal Ministry for the Environment to issue statutory regulations for this purpose.
The fee modulation is not expected to come into effect until 2028. An earlier start would be possible, albeit highly ambitious.

Two pieces of legislation, one key date

12 August 2026 is usually associated with the date on which the PPWR comes into force. Equally important: on the same day, the Packaging Act Implementation Act (VerpackDG) also came into force, replacing the Packaging Act (VerpackG), which had been in force since 2019.

The provision on the eco-design of participation fees has been transferred from Section 21 of the VerpackG to Section 26 of the VerpackDG. The requirement for the ZSVR to publish a minimum standard annually by 1 September is now set out in Section 26(3) of the VerpackDG.

Both instruments are temporary. They apply only until the delegated acts under Article 6 of the PPWR take effect. The European Commission must adopt these by 1 January 2028. The ‘Design for Recycling’ requirements of the PPWR itself will take effect from 1 January 2030 at the earliest. The national regulation under the VerpackDG therefore remains relevant until then.

Minimum standard 2026

Little new regarding materials

For flexible packaging materials such as those produced by ppg >, the material-specific framework in the new minimum standard remains largely unchanged. The revision is clearly aimed at bringing the system further into line with the PPWR. Consequently, some definitions have been clarified, various details consolidated and individual classifications refined.

However, the changes have no impact on the composites supplied by ppg > or on the assessment of their recyclability.

From a ‘market standard’ to a legal obligation

The most significant change is likely to be found in Section 26a of the Packaging Act (VerpackDG). This obliges the Federal Ministry for the Environment, in consultation with the Ministry for Economic Affairs and with the approval of the Bundesrat, to issue a statutory order. This order is to set out provisions governing how participation fees are to be structured in an environmentally sound manner in future.

The regulation is to include an obligation for systems and manufacturers (under Section 7 of the Packaging Act) to apply the minimum standard. Until now, application has effectively been directed at the dual systems. In future, it will also apply directly to distributors.

In addition, the regulation may specify certain amounts that the systems must take into account when calculating fees.

This brings within reach what has been envisaged in Germany since 2019 under Section 21 of the Packaging Act (VerpackG): a uniform, nationwide structure for licence fees for different packaging materials based on their recyclability. This had not yet been implemented, as specific guidelines on the structure were lacking, which is why the systems have continued to calculate their surcharges and discounts independently.

What will change from 2027

The basis for calculation will change with effect from 1 January 2027. As always, the new minimum standard applies to packaging placed on the market in the year following its publication. The 2026 minimum standard was published on 31 August 2026 and thus, as usual, immediately prior to the announcement of the dual systems’ fee calculations for the following year.

The fee regulation itself is not expected to come into force until 2028. At present, no information is available regarding a draft bill or similar document. The process must therefore still go through inter-ministerial consultations, consultations with the federal states and industry associations, and is expected to require EU notification and the approval of the Bundesrat.

In a resolution dated 12 June 2026, the Bundestag called for the statutory instruments to be submitted as soon as possible and set the introduction of eco-modulation from 2027 as a target (bundestag.de). Whether this will be achieved depends on how the process unfolds, right up to approval by the Bundesrat.

For this reason, the entry into force of the new fees regulation from January 2027 can be regarded as highly ambitious, whilst an adjustment from 2028 onwards is considered more likely.

Your contact

Jan Grevé

Head of Marketing and Communication

T: +49 (0) 441 / 50 50 29 40

E: jan.greve@prepacgroup.de

^Sources:
^{Verpackungsrecht-Durchführungsgesetz (VerpackDG), BGBl. I 2026 Nr. 207 vom 17. Juli 2026 · Verordnung (EU) 2025/40 (PPWR) · Mindeststandard für die Bemessung der Recyclingfähigkeit von systembeteiligungspflichtigen Verpackungen nach § 26 Abs. 3 VerpackDG, ZSVR, 31. August 2026}