German Packaging Act vs PPWR: what changes in 2026?

The short version first: the PPWR does not replace the German Packaging Act, it adds to it. From 12 August 2026 both apply to you in parallel — the familiar national registration and scheme participation on one side, the new EU-wide product conformity per packaging item on the other. Your LUCID registration and your contract with a dual system do not release you from the new PPWR obligations. If you have the VerpackG under control today you are halfway there — the other half comes on top.

Does the PPWR replace the German Packaging Act?

No — not entirely. The PPWR (Regulation (EU) 2025/40) has applied directly since it entered into force on 11 February 2025 and becomes applicable in the bulk of its provisions from 12 August 2026 (Art. 71). It repeals the old EU Packaging Directive 94/62/EC on which many national rules are based. The German VerpackG, however, remains in place in its enforcement function: registration, dual systems and supervision continue nationally. The PPWR lays a second, product-related layer of obligations on top.

What is the VerpackDG — and how does it relate to the VerpackG?

On 12 August 2026 the VerpackG is largely superseded by the VerpackDG (the German Packaging Implementation Act). The change of name is the most common source of confusion: this is not an entirely new regime but the national adaptation to the PPWR. Because an EU regulation applies directly and no longer has to be transposed into national law, the national statute shrinks from a self-standing body of rules (VerpackG) to an implementing act (VerpackDG) that flanks the PPWR — for instance where the regulation assigns tasks to the member states (registers, dual systems, penalties).

In practice that means: when people talk about the “VerpackDG” from 2026, they mean the same national enforcement framework you know from the VerpackG — LUCID, scheme participation, ZSVR — just under a new name and docked onto the PPWR. The substantive product requirements then sit in the PPWR itself.

What stays the same (LUCID, dual systems, ZSVR)?

The national mechanics that online retailers and companies placing goods on the market have known for years remain in place at their core and are continued through the VerpackDG. Anyone correctly registered and participating in a scheme today does not lose that status — from 2026 it simply no longer suffices on its own.

• LUCID registration: still free and mandatory before first placing on the market. No registration, no sale.
• Dual systems / scheme participation: participation in one or more dual systems for household packaging remains in place.
• ZSVR (the German central packaging register agency): remains the national supervisory and register authority.
• Deposit on single-use beverage packaging: the national single-use deposit continues unchanged.
• Annual data report: the volume report to the register remains a recurring obligation.

What is new under the PPWR?

What is new is a product-related conformity layer that did not exist under the VerpackG alone. Instead of “merely” registering and paying for the volume of a packaging item, under the PPWR you have to evidence that every single piece of packaging meets the EU requirements — comparable to the CE logic for products.

• Technical documentation per packaging item (Annex VII) — evidence that design, recycling and material requirements are met.
• Conformity assessment and EU declaration of conformity (DoC) under Art. 39 and Annex VIII — the formal evidence of PPWR conformity.
• Directly applicable design and recyclability requirements (Art. 6), staggered into performance grades.
• Minimum recycled content for plastic packaging (Art. 7).
• Harmonised labelling requirements (Art. 12) — uniform across the EU instead of inconsistent nationally.

These requirements apply directly in every member state by virtue of the regulation. Packaging conforming in Germany is therefore in principle marketable across the whole Union (Art. 4) — that is the flip side and the benefit of harmonisation.

Do the VerpackG/VerpackDG and the PPWR apply in parallel?

Yes, both apply in parallel. From 12 August 2026 you have to serve two layers at once: national registration and scheme participation (VerpackDG) AND EU product conformity (PPWR). Neither layer replaces the other. LUCID registration plus a dual system satisfy your national obligations — but they say nothing about whether your packaging meets the PPWR product requirements.

Why is scheme participation no longer enough from 2026?

Because scheme participation and product conformity answer two different questions. Scheme participation finances the collection and recovery of your packaging — it is a volume and fee obligation. The PPWR asks in addition: does this specific packaging item meet the design, recycling and recycled-content requirements, and can you evidence that with technical documentation and an EU declaration of conformity? Paying the scheme fee changes nothing about the conformity of the packaging itself.

What changes for EPR fees?

Extended producer responsibility (EPR) remains in place as a principle — what is new is how it interlocks with the PPWR. The eco-modulation of EPR financial contributions is tied to the PPWR recyclability grades (Art. 6(8)): more recyclable packaging will pay less in future, less recyclable packaging more. Packaging design therefore directly steers your fee burden. Companies that know and document the recyclability of their packaging can actively influence costs.

PPWR date of application

12 August 2026 (Art. 71)

PPWR entry into force

11 February 2025 (not 22.01., the publication date)

VerpackG → VerpackDG

from 12.08.2026, national adaptation to the PPWR

Stays national

LUCID, dual systems, ZSVR, single-use deposit, data report

New (EU-wide)

DoC, technical documentation, design/recycling/recycled-content/labelling requirements

Fee linkage

EPR eco-modulation tied to PPWR recyclability grades (Art. 6(8))

What do existing customers have to do now?

If you are VerpackG-compliant today, your national layer is largely secure. The work of the coming months sits on the new PPWR product layer: understanding which conformity evidence you need for which packaging, and building the data basis for it.

• Continue LUCID registration, scheme participation and deposit obligations unchanged — the national layer stays.
• Take an inventory of the packaging portfolio: which packaging, which materials, which role (producer, importer, distributor).
• Check PPWR applicability per packaging item: recyclability (Art. 6), recycled content (Art. 7), labelling (Art. 12).
• Prepare technical documentation and the EU declaration of conformity (Annexes VII/VIII, Art. 39) — the new DoC obligation.
• Assess recyclability, because through eco-modulation it will steer the EPR fee (Art. 6(8)).
• Watch the legal acts: many detailed deadlines hang on implementing and delegated acts still to be adopted.

Important: the legal classification of your specific role and obligations belongs in the hands of your law firm or specialist department. This article sets out the layers but does not replace legal advice.

Anyone who has the VerpackG under control loses nothing — but from 2026 has to serve a second, product-related layer of evidence. Scheme participation is obligation A, PPWR conformity is obligation B.

• Regulation (EU) 2025/40 (PPWR), OJ L 2025/40 of 22.1.2025 — in particular Art. 4, 6, 7, 12, 39, 44, 45, 70, 71; Annexes VII and VIII.
• VerpackG / VerpackDG (national transposition and enforcement: LUCID, dual systems, ZSVR, single-use deposit).
• As at July 2026. Not legal advice; check national transposition and role assignment on the facts.