Packaging Act: New authorisation regime for non-household packaging

On 17 July, Germany published the Packaging Law Implementation Act (VerpackDG), which replaced the Packaging Act (VerpackG) with effect from 12 August, and adapts national packaging legislation to the EU’s PPWR.

The existing system for packaging typically arising from households (termed “packaging subject to system participation” or “systembeteiligungs-pflichtige Verpackungen”) and comparable sources largely continues.

However, the Act makes several significant changes:

Non-household packaging

From 1 January 2028, producers of packaging not subject to system participation – including many types of transport and commercial packaging – must either transfer their EPR obligations to an authorised other PRO (“sonstige Organisation für Herstellerverantwortung” or sOfH) or obtain ZSVR authorisation for individual compliance. sOfHs are also authorised by the ZSVR and are subject to collection, financial control and financial guarantee requirements.

PROs

Existing PROs managing “packaging subject to system participation” (i.e. household packaging) remain authorised by the competent state authorities, but must meet additional operational and financial requirements, including adequate sorting and recycling capacity and a financial guarantee. Higher recycling targets apply from 2028.

Industry solutions

The existing alternative allowing producers to organise takeback from specified commercial/institutional sources (termed “industry solutions” or “Branchenlösungen”) is retained but is now subject to ZSVR authorisation. Solutions may operate without authorisation only until 31 October 2027.

Packaging prevention

PROs, sOfHs, industry solutions and individual compliers must implement and annually document packaging waste prevention measures, including measures supporting reuse and refill.

Foreign producers

Companies without a German establishment that sell directly to German end users must appoint an Authorised Representative (AR).

LUCID

Existing registrations remain valid, but producers must update their registration details by 12 November 2026. Producers newly subject to registration must register by 12 September 2026.

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