What is the VerpackDG?

Effective August 12, 2026, the Packaging Law Implementation Act (VerpackDG) and the EU Packaging Regulation (PPWR) will redefine how companies in Germany must handle packaging. What is behind these laws—and what do they mean in practice?

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Background.

Why is there a new VerpackDG?

The previous Packaging Act (VerpackG) was based on a 1994 EU Packaging Directive. More than 30 years later, the European Union has fundamentally revised this framework with Regulation (EU) 2025/40, known as the PPWR (Packaging and Packaging Waste Regulation).

Unlike the old directive—which set only minimum standards and left member states considerable leeway—the PPWR is an EU regulation. It will apply directly in all 27 EU member states as of August 12, 2026, without the need for national parliaments to pass their own laws. Germany still needs the VerpackDG, however, to adapt existing German structures—the LUCID packaging register, the dual systems, and the deposit system—to the new EU requirements.

The Packaging Act (VerpackDG) – In a Nutshell

The Packaging Law Implementation Act (VerpackDG) is the new German law that will replace the current Packaging Act (VerpackG) as of August 12, 2026, and incorporate the EU Packaging Waste Regulation (PPWR) into national law—with stricter requirements for registration, take-back, recycling rates, and labeling for virtually all companies that place packaging and packaged products on the market in Germany.

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Goal of the PPWR

By 2030, packaging waste in the EU is to be reduced by 5% (base year 2018), by 10% by 2035, and by 15% by 2040. At the same time, recycling rates are to increase significantly, and single-use formats are to be phased out of the market.

VerpackDG vs. PPWR.

What is the difference between VerpackDG and PPWR?

These two terms are often confused. Here is a clear distinction between them:

EU Packaging Regulation (PPWR)

The PPWR has been in effect since February 11, 2025, and will apply in all EU member states starting August 12, 2026—without requiring national implementation. The regulation establishes uniform Europe-wide standards for recyclability, labeling, the use of recycled materials, reusable packaging, and prohibited packaging formats.

Packaging Law Implementation Act (VerpackDG)

The VerpackDG transposes the new European packaging requirements of the PPWR into German law. It builds on established structures such as LUCID, the dual systems, and the deposit system, and significantly expands the requirements for obligated companies. The law was published in the Federal Law Gazette on July 17, 2026, following the conclusion of the parliamentary process. It entered into force as scheduled on August 12, 2026—coinciding with the effective date of the key provisions of the EU Packaging Regulation (PPWR).

Important

Both the EU Packaging Regulation (PPWR) and the German Packaging Act (VerpackDG) took effect on August 12, 2026, meaning that companies are now required to comply with both sets of regulations simultaneously.

Schedule.

What are the relevant deadlines?

The legislative process is underway, but the deadline has been set. In addition, there are phased deadlines for recycling rates through 2030.

February 2025

EU Packaging Regulation Takes Effect

The PPWR (EU) 2025/40 enters into force and will apply directly starting in August 2026.

February 11, 2026

Cabinet Decision on the Packaging Act (VerpackDG)

The federal government adopts the draft bill. This is followed by notification under European law.

July 10, 2026

Vote in the Bundestag and Bundesrat

The Bundestag has approved the bill; its key provisions are now finalized.

August 12, 2026

Effective Date – Date of Entry into Force

The EU Packaging Directive and the Packaging Act (VerpackDG) apply. Companies must be compliant, regardless of the status of the legislation.

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Note: An EU-wide implementing act regarding the harmonized registry is in the planning stages. Once adopted, national legislators will have 18 months to bring their laws into compliance—further changes are possible.

The law continues to evolve

We'll keep you updated.

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Types of Packaging.

What types of packaging are Affected?

Essentially, all packaging placed on the market in Germany—with a particular focus on commercial and industrial packaging, which has been subject to relatively few regulations to date. If you work with, manufacture, or even simply place any of the following products on the market, please read on carefully!

Packaging Subject to and Not Subject to System Participation Requirements

Retail Packaging

Packaging sold to industrial end users at the point of sale. Expanded labeling and recyclability requirements.

Service Packaging

Packaging filled at the point of sale (e.g., disposable cups, to-go containers). Some of which are subject to the prohibition annex of the PPWR.

Outer packaging

Additional packaging that holds together multiple retail units

Shipping Packaging

Packaging that protects goods during transport and typically ends up as waste at the industrial end-user

Primary production packaging

Packaging specifically designed and intended for unprocessed products from primary production (such as agriculture, fisheries, or forestry).

Packaging for E-commerce

Single-use packaging

Packaging designed for single-use only and disposed of or recycled after use

Reusable Packaging

Packaging that is specifically designed and engineered to undergo multiple cycles during its life cycle

Prohibited Formats (Annex V of the PPWR): Certain single-use formats will be completely banned starting in 2030. Companies should check now to see if their packaging is affected—a redesign takes time.

Is your company affected? Learn more

Duties.

What obligations apply to manufacturers, bottlers, and/or Distributor of industrial packaging?

The core provision of the new law: Anyone who places packaging on the market is responsible for its take-back and recycling—including in the B2B sector.

What Manufacturers and Distributors Must Do

Take-Back, Recycling, and Documentation Requirements

Commercial and industrial packaging is subject to take-back and recycling requirements under the Packaging Act (VerpackDG). In addition, this process must be thoroughly documented and verified.

Registration in the LUCID Registry

Manufacturers and distributors must register with the ZSVR’s LUCID Registry before packaging is placed on the market for the first time.

EU Authorization for the German Market

Companies without a branch in Germany that distribute packaging on the German market must appoint an authorized representative to fulfill their EPR obligations. In Germany, RIGK can also assume this role.

Meet Recycling Targets

The phased targets (75% starting in 2028, 80% starting in 2030) must be verified on a material-by-material basis.

What Applies Now

Extended Producer Responsibility

Extended Producer Responsibility (EPR) requires manufacturers and distributors to take responsibility for the entire life cycle of their products, particularly the financing and organization of take-back, recycling, and disposal.

In addition, EPR obligations include, for example, registration in the LUCID Registry.
The goal is to reduce waste, conserve resources, and strengthen the circular economy.

What should I do now? Learn more here

Duty to Provide Evidence.

What kind of reporting is Required?

Packaging compliance isn't just about doing the right thing—it's also about being able to provide complete documentation of it. The new law sets clear requirements for documentation and reporting.

Quantity Report

Annual reporting of the quantities of packaging placed on the market, broken down by material and category. Basis for calculating recycling rates.

Proof of Recycling

Proof that the collected packaging was actually recycled—through certificates from the recycling facility or certified systems such as RIGK.

Proof of Registration

Proof of registration with the competent authority and membership in an approved take-back system prior to the product’s initial placing on the market.

Proof of Recyclability

Proof that packaging meets the new EU recyclability criteria. Greenwashing claims such as “recyclable” must be substantiated.

Reporting to Regulatory Authorities

Regular reports to the competent authorities—the frequency and format are specified in the Packaging Act (VerpackDG) and the EU implementing acts.

Record-Keeping Requirements

All records and supporting documents must be retained for a specified period and made available during inspections. Specific time limits will be specified in the final text.

RIGK Tip: Anyone who handles take-back and recycling through RIGK automatically receives all necessary documentation and certificates—no separate documentation is required.

Risks & Consequences.

What are the consequences of noncompliance?

Companies that violate existing laws risk, for example, fines or bans on placing products on the market.

Risk Level – High

Possible penalty: administrative offense, fine, sales suspension

Possible penalty: fine, obligation to make back payments, withdrawal from the market

Possible penalty: sales ban, fine

Government enforcement is increasing

With the introduction of the new registry and the licensing requirement for system operators, oversight is becoming more systematic. Unregistered companies are being identified.

No Grace Period for Lack of Knowledge

The obligations take effect as of the effective date—regardless of whether a company was aware of the regulation. Early review provides protection.

Risk Level – Medium

Possible penalty: fine, official audit, obligation to provide evidence

I'm affected. Now what?

Our free webinar provides guidance and an overview—clear, practical, and immediately actionable. Or speak directly with our experts during a personalized initial consultation.

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FAQ: The Packaging Act

The most common questions companies ask us about the law.

The Packaging Law Implementation Act (VerpackDG) is the national regulation implementing the European Packaging Regulation (PPWR) in Germany. The VerpackDG specifies the requirements of the PPWR and further develops existing packaging law.

For companies, this primarily means greater obligations in fulfilling their responsibilities. Issues such as packaging take-back, recycling, producer responsibility, authorization, and record-keeping are being formalized to a greater extent. This is particularly relevant for companies that place packaging on the market in the commercial or industrial sectors.

Anyone who fails to comply with legal obligations must expect significant consequences. Failure to register, participate, or obtain approval, or submission of incomplete documentation, may result in packaging or packaged products being deemed unmarketable.

Possible consequences include, among others:

Sales bans
Fines
Prohibition on making the product available on the market
Withdrawal or recall measures
Additional regulatory and economic risks

It is therefore crucial for companies to implement their legal obligations reliably—not only formally but also operationally.

For companies, August 12, 2026, is a particularly important deadline. By that date, roles, types of packaging, responsibilities, and internal processes should have been clearly reviewed and documented.

Anyone placing packaging on the market in Germany should ensure well in advance that all relevant requirements regarding compliance, organization, documentation, and take-back are met on time. Delayed preparation can lead to operational and legal risks.

The Packaging Act (VerpackDG) primarily applies to packaging for which companies in Germany must fulfill take-back, recycling, and/or reporting obligations. These include, in particular:

packaging subject to mandatory participation in a recycling system
packaging not subject to mandatory participation in a recycling system
Retail packaging
Service packaging
Outer packaging
Transport packaging
Primary production packaging
Packaging for e-commerce
Disposable packaging
Reusable packaging

The Packaging Act (VerpackDG) is becoming significantly more relevant, particularly for companies whose packaging is not subject to mandatory participation in a recycling system.

RIGK handles all operational aspects of take-back, recycling, documentation, and reporting for B2B packaging. The company must complete the formal registration in the LUCID system on its own—RIGK provides support in this process. Certain obligations, such as the recyclability assessment of your packaging, must be initiated by the company; here, too, RIGK provides advice and guidance.

Possibly. The Packaging Act (VerpackDG) expands the scope of packaging categories subject to registration—particularly in the B2B sector. If you were previously registered only for B2C packaging, you’ll need to check whether any new categories have been added and update your registration accordingly.

Failure to register and failure to actively implement a take-back program for packaging materials can result in fines of up to €200,000 and immediate sales bans. In addition, there is a risk of reputational damage, as the lack of registration is visible in the public LUCID registry.

The cost of participating in the system depends on the type and quantity of packaging and packaged products placed on the market. RIGK will prepare a quote for you based on the information you provide and our licensing fees.

Violations of the Packaging Act (VerpackDG)—in particular, failure to register or noncompliance with EPR obligations—can result in fines of up to €200,000. In addition, there may be immediate sales bans as well as reputational damage resulting from public registries of unregistered companies.

Yes. The new Packaging Act (VerpackDG) does not include a provision for small quantities and makes no distinctions based on company size or revenue. Even small business owners and sole proprietors are subject to these obligations if they place packaging subject to the packaging system requirement on the market on a commercial basis.

Yes. Extended producer responsibility also applies to commercial, industrial, and agricultural packaging—regardless of whether private end consumers are involved. Anyone who places such packaging and packaged products on the market in Germany for the first time is subject to the legal obligations mentioned above.

Since the EU Packaging Regulation (PPWR) and the German Packaging Act (VerpackDG) took effect on August 12, 2026, registration and participation in a recycling system must already be fully completed. Companies that have failed to do so must act immediately to avoid warnings and sales bans. If packaging redesigns are necessary due to new requirements (such as the ban on certain single-use formats), these projects must be implemented now with the highest priority, as such a process—including coordination with suppliers—typically takes 12 to 18 months.

In principle, all packaging and packaged products placed on the market in Germany:

packaging subject to mandatory participation in a recycling system
packaging not subject to the system
Retail packaging
Service packaging
Outer packaging
Transport packaging
Primary production packaging
Packaging for e-commerce
Disposable packaging
Reusable packaging

A new development is that packaging that was not previously subject to mandatory participation in a recycling system may now fall within the scope of the regulation.

Administrative offenses, fines, and operational risks—such as those resulting from missing permits or incomplete supporting documentation.  In addition, there is a risk of reputational damage, as recyclability and “greenwashing” claims are subject to stricter scrutiny.

Yes. Online retailers place packaging on the market through their shipping materials and are subject to the same obligations as brick-and-mortar retailers. This also applies to retailers on marketplaces such as Amazon or eBay, provided they ship the goods themselves. Fulfillment service providers may also be affected under certain conditions.

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* Note: The information provided on this landing page offers an initial overview of the European Packaging Regulation (PPWR) and the national implementing law in Germany, the Packaging Law Implementation Act (VerpackDG). It is intended to provide guidance on the key obligations, responsibilities, and the solutions offered by RIGK. The content is not exhaustive and does not replace an individual assessment of a specific case or legal advice.