Verpackungsgesetz 2026: How Germany's VerpackDG and the EU PPWR Create a Two-Layer Compliance System

If you've been searching for "neues Verpackungsgesetz 2026" or "Verpackungsverordnung 2026," here is the precise answer: Germany no longer has a standalone Verpackungsgesetz in the traditional sense. As of 12 August 2026, two instruments govern packaging compliance simultaneously - and understanding how they divide responsibilities is the single most important compliance task for any company placing packaging on the German market right now.

What Just Happened: VerpackG Is Replaced by VerpackDG

The Bundestag passed the Verpackungsrecht-Durchführungsgesetz (VerpackDG) on 11 June 2026, and the Bundesrat adopted it on 10 July 2026. It was published in the German Federal Law Gazette on 17 July 2026. The VerpackDG replaces the former Verpackungsgesetz (VerpackG) and takes effect on the same date as the EU PPWR: 12 August 2026.

Why a new law at all? Because the PPWR (Regulation (EU) 2025/40) is an EU regulation, not a directive. It applies in all EU Member States from 12 August 2026 without any need for national transposition. Member States can only pass national legislation to cover areas where the PPWR deliberately leaves room for national decisions - such as producer registers, deposit systems, and EPR schemes. That is precisely what the VerpackDG does.

Layer 1: What the VerpackDG Preserves from the Old VerpackG

The German legislator's stated goal was to retain as much of the existing VerpackG infrastructure as possible. When adapting national law, the existing provisions of the Packaging Act were kept to the greatest extent possible - particularly the established extended producer responsibility systems. In practice, four core obligations carry over:

1. LUCID Registration with ZSVR

The VerpackDG cements the position of the Zentrale Stelle Verpackungsregister (ZSVR) as the national supervisory authority. The LUCID database remains the central control instrument, and every manufacturer placing packaging on the German market must be registered there - even though the substantive requirements are now defined in Brussels.

The VerpackDG contains a transitional provision: companies already registered in LUCID have until 12 November 2026 to update their registration to reflect the new rules.

2. System Participation (Lizenzierung)

Companies must sign a contract with a state-approved dual system provider, paying a fee to license their annual packaging volumes and material types. The VerpackDG secures the continued functioning of the dual systems (Gelbe Tonne/Gelber Sack) and regulates the coordination agreements between private system operators and public waste management bodies.

One significant change: transport packaging will now be included in the scope of system participation obligations, and all shipping packaging is set to become subject to mandatory system participation.

3. Data Reporting

Companies are required to regularly report their licensed packaging volumes and the name of their dual system to the LUCID register, ensuring full transparency. This obligation cannot be delegated - data reporting (the annual submission of packaging quantity data to LUCID/ZSVR, broken down by material type) must be carried out personally by the manufacturer for each Member State and each legal entity subject to registration.

For the 2026 reporting year specifically: there will be no separate declarations under old and new law. Instead, companies must report their volumes separately for the periods before and after 12 August 2026.

4. Vollständigkeitserklärung (Declaration of Completeness)

The audited Vollständigkeitserklärung (VE) survives into the VerpackDG. The obligation to file declarations of completeness applies to companies whose packaging volumes in the previous calendar year reached or exceeded at least one of the following thresholds: 80,000 kg of glass, 50,000 kg of paper/cardboard, or 30,000 kg of lightweight packaging (plastics, aluminium, composites) in total.

The ZSVR is expected to update its audit guidelines for the Vollständigkeitserklärung to align with the new packaging law. Key new focus areas in the 2026 VE audit will include: the delineation of packaging types (especially regarding system participation obligations), reporting volumes before and after 12 August 2026, and classification under the new PPWR terminology - with transport packaging now included in the audit scope.

Layer 2: What the PPWR Adds (and Overrides)

What may initially appear to be an extension of the familiar Packaging Act is, in reality, a structural shift in the regulatory system: the PPWR introduces a new role-based model that reallocates obligations and regulates product responsibility for packaging in a binding manner at EU level.

New "Producer" Definition - Who Is Responsible Changes

With the PPWR coming into effect, the definition of a producer and the scope of Extended Producer Responsibility will change. Retailers will become responsible for the packaging of their own brand products and imported goods. With PPWR applying, the manufacturer status for packaging of own-brand products and imported third-party brands without a domestic intermediary shifts to the retailer. This was confirmed by the EU Commission in a statement in June 2026.

Design for Recycling & Recyclability Grades

The PPWR introduces a classification system from Grade A to E - only packaging rated Grade C or above will be permitted. From 1 January 2030, only packaging achieving a minimum recyclability performance grade of C may be placed on the EU market. The grading system is set out in Annex II of Regulation (EU) 2025/40 and measures the proportion of a packaging unit, by weight, that can be effectively recycled.

Recycled Content Targets for Plastic Packaging

From 1 January 2030, the PPWR mandates minimum recycled content in plastic packaging: 30% for single-use PET beverage bottles, 30% for other contact-sensitive PET packaging, 10% for contact-sensitive packaging from other plastics, and 35% for all other plastic packaging. The European Commission must adopt implementing acts by 31 December 2026 establishing the official methodology for calculating, verifying, and certifying recycled content - meaning the precise measurement rules are still being developed.

Packaging Minimization

Unnecessary packaging must be removed from the market. Weight, volume, and empty space must be reduced to the functional minimum. For e-commerce packaging, the empty space ratio must not exceed 40% from August 2026.

Declaration of Conformity (DoC)

A Declaration of Conformity (DoC) is a written declaration by the packaging manufacturer confirming that the packaging meets the requirements of Articles 5 to 12 of Regulation (EU) 2025/40. The DoC covers the full scope of Articles 5 to 12 of the PPWR - including packaging minimisation (Article 5), reusability and refillability (Articles 6-9), recyclability (Article 10), recycled content (Article 11), and labelling (Article 12).

A DoC is required for every packaging unit and must be retained for five years (single-use packaging) or ten years (reusable packaging).

Future: EU-Level Registry Replaces LUCID

By 2029, national packaging databases such as Germany's LUCID will be replaced by a single EU-level registry for producers and distributors, designed to streamline transparency and enforcement.

How the Two Layers Interact: A Side-by-Side View

Penalties and Enforcement in Germany

National laws in EU Member States cannot change or repeat harmonised PPWR rules - they can only add rules in areas where the PPWR gives Member States a choice. Penalties are one such area. The PPWR itself does not specify penalty charges, meaning all individual Member States regulate these at national level. Germany's VerpackDG provides for fines starting from €10,000 up to €200,000 per violation.

Market surveillance - verifying whether packaging on the market actually meets PPWR requirements - falls under the competent authorities of the federal states (Länder). The ZSVR actively refers suspected cases of non-compliance to these state-level authorities.

Beyond fines: companies may also face official sales bans and competition-law warnings from compliant competitors. The VerpackDG authorizes the ZSVR to conduct automated data matching with the dual systems and tax authorities to identify free-riders.

The Data Problem at the Center of Both Layers

Both the VerpackDG and the PPWR converge on one requirement: structured, auditable packaging data. The VerpackDG demands accurate volume reporting by material type. The PPWR demands a DoC backed by technical documentation covering minimization, recyclability, recycled content, and substance restrictions - for every packaging type, across primary, secondary, and tertiary packaging.

Under Article 18 of the PPWR, national and European authorities can request DoC documentation at any time and companies must respond within ten days.

Most companies today manage this data in Excel, ERP exports, and scattered PDFs. That approach cannot produce a ten-day-turnaround DoC response at scale, nor can it generate the split volume reports required for the 2026 Vollständigkeitserklärung (pre- and post-12 August).

What to Do Now

The two-layer system is live. Here is the priority sequence:

1. Verify your LUCID registration reflects the new VerpackDG producer definitions - especially if you sell own-brand or imported products without a German intermediary. Transition deadline: 12 November 2026.
2. Audit your system participation scope - transport and shipping packaging may now be subject to mandatory system participation under the new ZSVR catalogue.
3. Prepare split volume tracking for your 2026 Vollständigkeitserklärung: you need separate figures for January-11 August and 12 August-31 December.
4. Issue or collect Declarations of Conformity for all packaging types. Primary, secondary, and tertiary packaging must each be covered separately.
5. Start recycled content documentation now - even though the 2030 targets are not yet enforceable, the implementing acts for measurement methodology are due by end of 2026, and supply chain data takes time to collect.

Frequently Asked Questions