PPWR penalties and fines: what you actually risk

If you do not meet the PPWR, you deal with market surveillance first: the authority can demand corrections, prohibit the sale and have packaging withdrawn or recalled. The amount of a fine is not set by the EU regulation but by national law. In Germany that has been the Packaging Law Implementation Act (VerpackDG) since 12 August 2026. This article gives the overview. The details are in the article “PPWR fines in Germany: tiers, amounts and dates under the VerpackDG”.

What happens if I do not comply with the PPWR?

In Germany the PPWR (Regulation (EU) 2025/40) is enforced by the market surveillance authorities of the federal states. If an authority finds a non-conformity, the European Commission expects it to ask for a remedy first. If none follows, the authority can prohibit the sale and order a withdrawal or recall. These powers exist today, regardless of when a fine can be imposed. For many companies the ban on sale is the heavier consequence: goods that may not be sold tie up capital and strain supply relationships.

In an inspection the authority usually asks for the EU declaration of conformity first and then for the technical documentation. Both are drawn up by the manufacturer of the packaging in question. The manufacturer must submit the documents electronically within ten days of a reasoned request (Art. 15(10)).

How high are the fines in Germany?

The PPWR itself names no amounts. The VerpackDG has three tiers with ceilings of €10,000, €100,000 and €200,000. Breaches of the PPWR conformity duties mostly fall into the tier up to €10,000, for example a missing or incomplete conformity assessment, or documents that are not kept or are submitted late. Up to €100,000 applies when a company disregards an enforceable order from the authority. The highest tier concerns duties such as scheme membership, not the declaration of conformity.

Legal basis in Germany

Section 66 VerpackDG

PPWR conformity duties

Subject to fines from 12 February 2027, mostly up to €10,000

Disregarded order

Up to €100,000

Additional consequence

Ban on sale, withdrawal or recall until remedied

From when can fines be imposed?

1. 12.08.2026

   PPWR and VerpackDG apply

   Market surveillance can establish non-conformity, order corrections and prohibit the sale. Breaches of national duties such as registration and scheme membership already carry fines.

2. 12.02.2027

   Fines for PPWR breaches

   From this day, breaches of the PPWR conformity duties also carry fines (Section 68(17) VerpackDG).

How do you protect yourself?

The best precaution is documentation you can submit at any time. Clarify for each packaging whether you are the manufacturer. If you are, keep the EU declaration of conformity up to date and the technical documentation under Annex VII complete. Also decide who answers requests from authorities within the ten-day period.

How a specific breach is assessed and how high a fine turns out is decided by the authority and national law.